United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
Washington, DC 20460
EPA 305-B-04-001
February 2004
&EPA
Compliance Assistance Tool for
Pharmaceutical Production, Pesticide Active
Ingredient Production, and Miscellaneous
Organic Chemical Manufacturing NESHAP:
Comparison of Regulatory Requirements and
Case Study Compliance Illustrations for
Nondedicated Equipment
Pharmaceuticals
Multi-Purpose
Process
Units
Organic Chemicals
r-
Other Additives
Pesticides
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Compliance Assistance Tool for
Pharmaceutical Production, Pesticide Active Ingredient
Production, and Miscellaneous Organic Chemical
Manufacturing NESHAP:
Comparison of Regulatory Requirements and Case Study
Compliance Illustrations for Nondedicated Equipment
February 2004
Office of Enforcement and Compliance Assurance
Office of Compliance
Compliance Assessment and Media Programs Division
Air, Hazardous Waste and Toxics Branch
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Disclaimer
The statements in this document are intended solely for compliance assistance. It is to be
used in conjunction with the regulations, not in place of them. This document is not intended,
nor can it be relied on, to create any rights enforceable by any party in litigation with the United
States. The U.S. Environmental Protection Agency (EPA) and State officials may decide to
follow the guidance provided in this document, or to act in variance with the guidance, based on
analysis of specific site circumstances. This guidance may be revised without public notice to
reflect possible rule changes and changes in EPA's policy.
Please be aware that the EPA has made its best effort to present an accurate summary of
regulatory requirements in the pharmaceutical production, pesticide active ingredient, and
miscellaneous organic chemical manufacturing MACT rules. Note, however, that it is not
intended to summarize every option and detail of the rules. For example, this document does not
describe requirements for new sources that differ from those for existing sources. In addition, in
the event that there are typing errors or deviations from the final rules, the final rules stand.
11
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Table of Contents
Section Page
I. Introduction 1
II. Background 1
A. Affected Source and Applicability 1
1. Pharmaceutical Manufacturing (PhRMA) MACT 2
2. Pesticide Active Ingredient (PAI) MACT 2
3. Miscellaneous Organic Chemical Manufacturing MACT 2
B. Regulated Emission Points and Control Requirements 3
C. Compliance Demonstration 11
D. Monitoring Requirements 11
E. Reporting and Recordkeeping 21
F. Summary of Specific Provisions for Overlapping Requirements 36
1. Consistency with NSPS for storage tanks in 40 CFR part 60, subpart Kb ... 36
2. Consistency with other MACT standards 36
3. Compliance with subparts I, GGG, or MMM 36
4. Compliance with subpart FFFF for affected wastewater 36
G. Summary of the Process Unit Group Option 36
III. Consolidation Approaches 38
Appendix A: Six Case Studies A-l
List of Tables
Table Page
1 Summary of Process Vent Emission Standards for Existing Sources in the PhRMA,
PAI, and MON MACT Rules 3
2 Summary of Storage Tank Emission Standards for Existing Sources in the PhRMA,
PAI, and MON MACT Rules 7
3 Summary of Wastewater Emission Standards for Existing Sources in Subparts GGG,
MMM, and FFFF 8
4 Summary of Emission Standards for Transfer Operations and Equipment Leaks for
Existing Sources Under the PhRMA, PAI, and MON MACT Rules 10
5 Comparison of Monitoring Requirements in Subparts GGG, MMM, and FFFF 12
6 Comparison of Recordkeeping Requirements in Subparts GGG, MMM, and FFFF 21
7 Comparison of Reporting Requirements in Subparts GGG, MMM, and FFFF 29
8 Summary of Relevant Overlapping Provisions 37
9 Summary of Case Studies 39
in
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List of Acronyms
APCD air pollution control device
BOD biochemical oxygen demand
CAR consolidated federal air rule
CCCD centralized combustion control device
CEMS continuous emissions monitoring system
CFR Code of Federal Regulations
CGMP current good manufacturing practice
C12 chlorine
CMS continuous monitoring system
CPMS continuous parameter monitoring system
CVS closed-vent system
DOT U. S. Department of Transportation
EDC ethylene dichloride
EPA U.S. Environmental Protection Agency
HAPs hazardous air pollutants
HC1 hydrogen chloride
FTP hydrogen fluoride
HON hazardous organic NESHAP
FEW hazardous waste
LDAR Leak Detection and Repair
M21 Method 21 of appendix A of 40 CFR part 60
MACT Maximum Achievable Control Technology
MCPU miscellaneous organic chemical manufacturing process unit
MON miscellaneous organic NESHAP
MTVP maximum true vapor pressure
NESHAP national emission standards for hazardous air pollutants
NOCS notification of compliance status
NSPS new source performance standards
O2 oxygen
P2 pollution prevention
PAI Pesticide Active Ingredient
PhRMA Pharmaceutical Manufacturing
PM particulate matter
PMPU pharmaceutical manufacturing process unit
POD point of determination
PS performance specifications
PSHAP partially soluble HAP
PUG process unit group
QA quality assurance
QC quality control
QIP quality improvement program
RATA relative accuracy test audit
RCRA Resource Conservation and Recovery Act
IV
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List of Acronyms (continued)
RMR required mass removal
SHAP soluble HAP
SIC standard industrial classification
SO2 sulfur dioxide
SSM startup, shutdown, and malfunction
SSMP startup, shutdown, and malfunction plan
TOC total organic compounds
TRE total resource effectiveness
TSS total suspended solids
Units of Measure
gal gallons
gr/dscf grains per dry standard cubic feet
hr/d hours per day
hr/yr hours per year
kg/hr kilograms per hour
kPa kilopascals
Ib/hr pounds per hour
Ib/yr pounds per year
1pm liters per minute
m3 cubic meters
Mg/yr megagrams per year
MM million
MW megawatts
ppm parts per million
ppmv parts per million by volume
ppmw parts per million by weight
psia pounds per square inch absolute
s seconds
tpy tons per year
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VI
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I. Introduction
Maximum Achievable Control Technology (MACT) standards for the control and
reduction of hazardous air pollutants (HAP) are established on a source category basis, typically
defined by the product(s) that are produced. Most MACT rules have equipment-based standards,
which means the requirements apply to a specific series or train of equipment, even if the
equipment is not dedicated to the production of a product in the subject source category.
However, the MACT rules for pharmaceuticals production, pesticide active ingredient
production, and miscellaneous organic chemical manufacturing (subparts GGG, MMM, and
FFFF, respectively, in 40 CFR part 63) are process-based standards. This means each standard
applies only when the equipment is used to produce a product in the source category subject to
that rule. Specialty chemical manufacturers often produce chemicals in at least two, and
sometimes all three, of these source categories. The chemicals also are often produced in
nondedicated, multipurpose equipment. As a result, there is the potential for the applicable rule
for a given piece of equipment to change when the source switches from the production of one
product to another. The overlapping requirements for a particular piece of equipment also
potentially complicate compliance demonstrations for the source.
To minimize the burden associated with these overlapping requirements, subparts GGG,
MMM, and FFFF were written with provisions that were intended to allow for the consolidation
of requirements under one rule. To evaluate the effectiveness of these provisions, the U.S.
Environmental Protection Agency (EPA) undertook a project to review the potential for overlap
and examine how sources could consolidate applicable requirements while also considering the
specialty chemical industry's need to quickly undertake process changes. We examined the
potential for overlap by obtaining detailed information on processing from two specialty
chemical facilities. Based on the information we obtained, we concluded that the rules as written
were generally amenable to consolidation of requirements. This document provides guidance on
possible approaches for simplifying and consolidating overlapping requirements.
II. Background
A. Affected Source and Applicability
Subparts GGG, MMM, and FFFF of part 63 are summarized below. They are similar in
format for requirements and affected sources and only apply to major sources of HAP and only
to processes that use, produce, or process HAP. These standards apply to multipurpose chemical
processors and have similar applicability and control requirements; if a facility manufactures
products that are subject to different MACT standards, there is the potential for equipment to be
subject to multiple MACT standards. This raises issues relating to difficulties associated with
complying with three standards and the obvious need for simplification, as well as to the
potential for facing a multitiered series of compliance strategies that may change as subsequent
MACT standards take effect. Applicability of the three standards are described below.
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1. Pharmaceutical Manufacturing (PhRMA) MACT
Subpart GGG of part 63, the Pharmaceutical Manufacturing MACT, was promulgated on
October 21, 1998. The compliance date of the standard for existing sources was October 21,
2002. The affected source is the collection of units that manufacture pharmaceutical "products,"
which is defined at §63.1251 as follows:
Pharmaceutical product means any of the following materials, excluding any material
that is a nonreactive solvent, excipient, binder, or filler, or any material that is produced
in a chemical manufacturing process unit that is subject to the requirements of 40 CFR
part 63, subparts F and G:
(1) Any material described by the standard industrial classification (SIC) code
2833 or 2834; or
(2) Any material whose manufacturing process is described by North American
Industrial Classification System code 325411 or 325412; or
(3) A finished dosage form of a drug, for example, a tablet, capsule, solution,
etc.; or
(4) Any active ingredient or precursor that is produced at a facility whose
primary manufacturing operations are described by SIC code 2833 or 2834; or
(5) At a facility whose primary operations are not described by SIC code 2833 or
2834, any material whose primary use is as an active ingredient or precursor.
2. Pesticide Active Ingredient (PAI) MACT
Subpart MMM of part 63 , the Pesticide Active Ingredient MACT, was promulgated on
June 23, 1999. The compliance date for existing sources is December 23, 2003. The affected
source is the collection of units that produce a material that is primarily used as a pesticide active
ingredient or integral intermediate. Pesticide active ingredients are substances that are defined
under section 2(a) of the Federal Insecticide, Fungicide, and Rodenticide Act. The term
"integral intermediates" refers to the production of materials for which 50 percent or more of the
annual production is used in the onsite manufacture of any pesticide active ingredients and not
"stored" before being used in the production of active ingredients or other integral intermediates.
Some processing steps that are conducted prior to the manufacture of the active ingredient may
be excluded from the PAI MACT. Additionally, formulation operations are specifically
excluded from the PAI affected source.
3. Miscellaneous Organic Chemical Manufacturing MACT
Subpart FFFF of part 63, national emission standards for hazardous air pollutants
(NESHAP) for miscellaneous organic chemical manufacturing (commonly referred to as the
miscellaneous organic NESHAP [MON]) was promulgated on November 10, 2003. The
compliance date for existing sources will be November 10, 2006. The affected source is the
collection of units that manufacture a range of miscellaneous organic materials or families of
materials that are described by a number of SIC codes as products or isolated intermediates. The
MON will generally regulate emission sources in organic chemical manufacturing that are not
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regulated under other MACT standards. Because the MON's compliance date is later than either
the PhRMA MACT or the PAI MACT, it will become the "catch all" MACT standard for
miscellaneous organic chemical processes that have not been regulated under earlier standards.
Therefore, an organic chemical manufacturing process that is not part of a PhRMA or PAI
affected source but is located at a major source that uses, produces, or processes HAP will most
likely be subject to the MON. The MON will also cover solvent recovery processes and
formulation processes that have previously been excluded from other MACT standards, such as
the hazardous organic NESHAP (HON) (which excluded batch vents and sources with only HAP
solvent emissions from its affected source) and the PAI MACT (which specifically excludes
formulation operations).
B. Regulated Emission Points and Control Requirements
Tables 1 through 4 summarize requirements for emission points that are relevant to this
discussion. The summary is limited to existing source standards. There are additional
differences for new source standards, but for simplicity, we have chosen not to discuss new
source standards because any conclusions drawn from the analysis for existing sources will
generally also apply to the new source standards. This listing does not represent a
comprehensive summary, but a summary of substantive control requirements. The formats of
the requirements are very similar. A major difference between the three rules is the applicability
thresholds for control of process vents, wastewater, and storage tanks, such that emission sources
may require controls under one standard and not under another. Control requirements vary only
slightly in stringency among the three standards.
Table 1. Summary of Process Vent Emission Standards for Existing Sources in
the PhRMA, PAI, and MON MACT Rules
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF (MON)
Batch
Continuous
Process Vents With Organic HAP Emissions
Threshold for
control
>0.90 Mg/yr total HAP
before control from
process,
>1. 80 Mg/yr total HAP
before control from
facility
[§63.1254(a)(2)]
>0. 15 Mg/yr before
control from process
[§63.1362(b)(2)(i>]
> 10,000 Ib/yr before
control from process
[Table 2 and
Definitions]
Vents with TRE
indices <5.0
[Table 1 and
Definitions]
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Table 1. Summary of Process Vent Emission Standards for Existing Sources in
the PhRMA, PAI, and MON MACT Rules (continued)
Control
Requirement
Subpart GGG
(PhRMA MACT)
Reduce total HAP
emissions to <0.90
Mg/yr per process, up to
1. 8 Mg per facility
[§63.1254(a)(2>]
Reduce total HAP per
process by > 93% except
reduce total HAP by
> 98% for any large
vent(s).
[§63.1254(a)(l)(i)and
(3)(i)]
Any vents within the
process may be excluded
from the percent
reduction requirement if
they are controlled
To < 20 ppmv as TOC
and <20 ppmv as
hydrogen halide and
halogen, or
Using a flare, boiler,
process heater, or RCRA
device, or
Using the alternative
standard
[63.1254(a)(l)(ii),(3)(i),
and (c)]
Subpart MMM
(PAI MACT)
Not applicable
Reduce organic HAP
per process by > 90%
except reduce organic
HAP by > 98% for any
large vent(s)
[§63.1362(b)(2)(i)and
(iii)]
Any vents within the
process may be
excluded from the
percent reduction
requirement if they are
controlled
To <20 ppmv TOC
or total organic HAP,
or
Using a flare,
boiler, process heater,
or RCRA device, or
Using the
alternative standard
[§63.1362(b)(2)(iv),
and (b)(6)]
Subpart FFFF (MON)
Batch
Not applicable
Reduce collective
organic HAP from any
group of vents within
the process by > 98%
using a control device,
or
Reduce collective
organic HAP
emissions from any
group of vents within
the process by > 95%,
or
For any vents not
controlled to meet
either of the percent
reduction options,
reduce organic HAP
emissions
To < 20 ppmv as
TOC or organic HAP,
or
Using the
alternative standard
[Table 2 and
§63.2505]
Note that a flare,
boiler, process heater
or RCRA device
meeting conditions
specified in §63.987
or 63. 988 satisfies the
percent reduction or
outlet concentration
standards.
Continuous
Maintain TRE
>1.9with
recovery device
[Table 1]
Reduce organic
HAP emissions
By > 98%, or
To <20 ppmv,
or
Using the
alternative
standard
[Table 1 and
§63.2505]
Note that a
flare, boiler,
process heater,
or RCRA device
meeting
conditions
specified in
§§63.987 or
63.988 satisfies
the percent
reduction or
outlet
concentration
standard.
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Table 1. Summary of Process Vent Emission Standards for Existing Sources in
the PhRMA, PAI, and MON MACT Rules (continued)
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF (MON)
Batch
Continuous
Additional Requirements for Halogenated Streams
Threshold for
control
If combustion device is
used for control
Uncontrolled HC1 and
C12, including
emissions of these
HAP generated by
combustion controls,
>6.8 Mg/yr/process
[§63.1363(b)(3)(i)]
Group 1 batch or continuous halogenated
streams for which a combustion control
device is used to control organic HAP
emissions [Definitions and Tables 1 and 2]
Control
Requirement
Reduce hydrogen
halides and halogens by
95% or to a
concentration <20 ppmv
after combustion control,
or reduce halogen atom
content to <20 ppmv
prior to combustion
[§63.1252(g>]
Reduce sum of HC1
andC!2by > 94% or to
<20 ppmv
[§63.1362(b)(3)(ii)]
Reduce hydrogen halides and halogens
after the combustion device by > 99%, to
<0.45 kg/hr, or to <20 ppmv, or
Reduce halogen atom mass emission rate
before the combustion device to <0.45
kg/hr or <20 ppmv device
[Tables 1 and 2]
Hydrogen halides and halogens
Threshold for
Control
Control
Requirement
The requirements are
included with other
process vent emissions
because the rule
specifies requirements
only for total HAP
[§63.1254(a>]
Same as for
halogenated vent
streams
Same as for
halogenated vent
streams, or
Alternative standard
[§63.1362(b)(6>]
>1,000 Ib/yr HC1, HF, and C12
uncontrolled per process [Table 3]
Reduce sum of emissions by > 99% or to
<20 ppmv [Table 3], or
Alternative concentration standard
requiring continuous emissions monitoring
system (CEMS) [§63.2505]
Hydrogenation Vents
Threshold for
Control
Control
Requirement
Hydrogenation vents
that are "large vents"
[§63.1254(a)(3)(ii)(Q]
95% overall control
[§63.1254(a)(3)(ii)(Q]
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
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Table 1. Summary of Process Vent Emission Standards for Existing Sources in
the PhRMA, PAI, and MON MACT Rules (continued)
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF (MON)
Batch
Continuous
PM HAP Vents
Threshold for
Control
Control
Requirement
Included with other
process vent emissions
because the rule
specifies requirements
only for total HAP
[§63.1254(a)]
For bag dumps and
product dryers drying
a PAI or integral
intermediate
[§63.1363(e)]
Reduce PM HAP to
<0.01 gr/dscf
[§63.1363(e)]
Not applicable for
existing sources
Not applicable
for existing
sources
Not applicable
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Table 2. Summary of Storage Tank Emission Standards for Existing Sources
in the PhRMA, PAI, and MON MACT Rules
Threshold for
control
Control
Requirement
Subpart GGG
(PhRMA MACT)
MTVP>13.1kPa:
>38 m3 design capacity (cap)
[§63.1253(a)]
90% for cap <75 m3;
95% for cap > 75m3;
20 ppmv outlet; or
floating roof [§63. 1253(b) and
(c)]
Alternative concentration
standard requiring CEMS
[§63.1253 (d)]
Enclosed combustion with 0.5 s
residence time and
>760°C [§63.1263((b)(3) and
(c)(3)]
Flare, boiler, process heater,
RCRA unit
[§63.1263((b)(4 and 5) and (c)(4
and 5)]
Vapor balancing [§63.1253(f)]
Subpart MMM
(PAI MACT)
MTVP>3.45kPa:
>75 m3 design capacity
(cap)
[Definitions]
95%;
20 ppmv outlet; or
floating roof
[§63.1362(c)]
Alternative
concentration standard
requiring CEMS
[§63.1362(b)(6)]
Not applicable
Flare, boiler, process
heater, RCRA unit
[§63.1362(c)]
Vapor balancing
[§63.1362(c)]
Subpart FFFF
(MON)
MTVP>6.9kPaand
capacity > 10,000 gallons
[Definitions]
95%;
20 ppmv outlet; or
floating roof (only if MTVP
<76.6 kPa)
[Table 4]
Alternative concentration
standard requiring CEMS
[§63.2505]
Return to process or fuel gas
system [Table 4]
Flare, boiler, process heater,
RCRA unit [Flares are
specifically listed in Table 4;
requirements for other devices
are specified in §63.985, which
is referenced from §63.2450(d)]
Vapor balancing [§63.2470(e)]
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Table 3. Summary of Wastewater Emission Standards for Existing Sources
in Subparts GGG, MMM, and FFFF
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Threshold for
control
Each POD with
> 1,300 ppmw and >0.25
Mg/yr partially soluble HAP
(PSHAP) load from the
PMPU;
> 5,200 ppmv and >0.25 Mg/yr
total PSHAP and soluble HAP
(SHAP) load; or
> 10,000 ppmw and > 1 Mg/yr
facility HAP load
[§63.1256(a)(l)(i)]
Each POD with HON
Group 1 criteria
> 10 1pm and > 1,000
ppmw for all
compounds listed in
Table 9 of the HON; or
> 10,000 ppmw at any
flowrate
[Definitions]
Each POD with
> 11pm and > 1,000
ppmw combined
PSHAP and SHAP,
> 30,000 ppmw and >1
tpy SHAP load, or
> 10,000 ppmw total
PSHAP and SHAP at
any flowrate
[§63.2485(c)]
Wastewater treatment requirements
Nonbiological
treatment options
For wastewater that contains
PSHAP: treat to <50 ppmw or
remove >99%;
[§63.1256(g)(8)]
For wastewater that contains
SHAP: treat to <520 ppmw or
remove >90%
[§63.1256(g)(9)]
Rule references subpart G
of the HON:
Design steam stripper
[§63.138(d)];
Reduce mass flow rate
of Group 1 by > 99% or
byFr;[§63.138(e)]
Treat to <50 ppmw
outlet [§63.138(b)] or
achieve RMR
[§63.138(f)]
Same as subpart MMM
Biological
treatment options
Enhanced biotreatment for
SHAP if wastewater contains
<50 ppmw PSHAP
[§63.1256(g)(10)]
> 95% overall control of all
PSHAP and SHAP sent to
biological treatment
[§63.1256(g)(ll)]
> 99% control of PSHAP and
> 90% control of SHAP in
affected wastewater
[§63.1256(g)(8)and(9)]
Enhanced biotreatment
[§63.145(h)(l)]if99%
of HAP are on List 1 of
Table 36 of HON
> 95% of all compounds
listed in Table 9 of the
HON that are sent to
biological treatment
[§63.138(g)]
Achieve RMR for
Group 1 wastewater
[§63.138(f)]
Same as subpart MMM
Other treatment
options
Offsite treatment or onsite
treatment not owned by source
[§63.1256(a)(5)];
Treatment in RCRA Unit
[§63.1256(g)(13)]
Offsite treatment or
onsite treatment not
owned by source
[§63.1362(d) references
§63.132])
Treatment in RCRA
Unit[§63.1362(d)
references §63.138(h)]]
Offsite treatment or
onsite treatment not
owned by source;
[§§63.132 and
63.2485(i)]
Treatment in RCRA
Unit [§63.138(h)]
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Table 3. Summary of Wastewater Emission Standards for Existing Sources
in Subparts GGG, MMM, and FFFF (continued)
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Emission suppression requirements for waste management units
Wastewater tanks
Use a fixed roof if contents are
not heated, treated by
exothermic reaction, or
sparged
If contents are heated, treated
by exothermic reaction, or
sparged, generally also must
vent emissions through CVS
to control or use floating roof.
However, if the heating,
exothermic reaction, or
sparging increases the
emissions by <5%, then a
fixed roof alone is sufficient
[§63.1256(b)(l)and(2)]
Comply with subpart G
Use fixed roof if
contents are not heated,
treated with exothermic
reaction, or sparged;
Otherwise:
- vent emissions
through CVS to control,
or
- use floating roof
[§63.133]
Same as subpart GGG
[§§63.2485(d)(3)and
63.133]
Surface
impoundments and
oil-water
separators
Vent emissions through a CVS
to control, or install a floating
membrane/roof.
[§63.1256(c)and(f>]
Same as subpart GGG
[§63.1362(d) references
§§63.134 and 63.137]
Same as subpart GGG
[Table 7 to subpart FFFF
references §§63.134 and
63.137]
Containers
Vent emissions from containers
>0.42 m3 through CVS to
control [§63.1256(d)]
Same as subpart GGG
[§63.1362 references
§63.135]
Same as subpart GGG
[Table 7 to subpart FFFF
references §63.135]
Drains
Vent emissions through CVS to
control [§63.1256(e)]
Same as subpart GGG
[§63.1362 references
§63.136]
Same as subpart GGG
[Table 7 to subpart FFFF
references §63.136]
Junction boxes and sewer lines
can be vented if equipped with
water seals [§63.1256 (e)(2)(iii)]
Not applicable
Same as subpart GGG
[§63.2485(e)(l)]
Options for offsite
waste management
units prior to
biological
treatment
Not required to cover waste
management units up to the
activated sludge unit if
wastewater contains less than 50
ppmw PSHAP, and the SHAP
losses are < 5% prior to the
activated sludge unit
[§63.1256(a)(5)(D)(J)and(O]
Same as subpart GGG
[§63.1362(d)(14)]
Same as subpart GGG
[§63.2485(i)(2)]
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Table 3. Summary of Wastewater Emission Standards for Existing Sources
in Subparts GGG, MMM, and FFFF (continued)
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Requirements for scrubber effluent
Scrubber effluent is an affected
wastewater stream if it is
discharged from a scrubber that
is used to control PSHAP from
process vents
[§63.1256(a)(l)(iii)]
Scrubber effluent is
included in the definition
of wastewater
None specified
Table 4. Summary of Emission Standards for Transfer Operations and Equipment Leaks
for Existing Sources Under the PhRMA, PAI, and MON MACT Rules
Emission Point
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Transfer Operations
Threshold for
control
Control
Requirements
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Loading rack for trucks or tank cars
>0.65 MM liters per year; and
material with > 10.3 kPa [Definitions]
98% or to <20 ppmv overall
[Table 5]
CVS to flare or fuel gas system
[Table 5]
Vapor balance [§63.2475]
Equipment Leaks
Threshold for
control
>300 hours/yr in HAP
service
>300 hours/yr in HAP
service
>300 hours/yr in HAP service
Control
Requirements
Subpart GGG LDAR,
or
Comply with subpart
H
[§63.1250(h)(4)]
Subpart MMM
LDAR, or
Comply with
subpart H
[§63.1260(i)(4)]
Subpart TT or UU if process has no
continuous vents;
Subpart UU for processes with at
least one continuous vent;
Part 65 subpart F (the CAR) for
any process; or
Comply with GGG, H, or MMM, if
other equipment is already subject
to one of these rules
[§63.2535(d) and Table 6 to Subpart
FFFF]
10
-------
C. Compliance Demonstration
Each of the rules also addresses the concept that emission control devices must be
demonstrated to be capable of achieving required control efficiencies under all processing
conditions. When a wide variation in emission stream characteristics is expected during the
course of batch operations, the intent of each of the rules is to require that a compliance
demonstration be conducted over the most challenging set of conditions that will be encountered
during operations; for equipment that is multipurpose, we expect that operators may be less
likely to have to conduct additional compliance testing to demonstrate compliance with all three
rules if they have developed a proper worst-case compliance demonstration that encompasses the
range of conditions expected to occur. The initial compliance demonstration provisions provide
two options for conducting a worst-case demonstration: (1) absolute, which is based on actual
operations, or (2) hypothetical, based on simulated conditions. Both options require the owner
or operator to determine the set of conditions that would present the greatest challenge to
achieving the required control efficiency. The rules offer some options for selecting these
challenging conditions, such as defined periods of highest possible combined HAP and volatile
organic compound load to the control device, or defining periods where HAP constituents will
not generally be amenable to control for the abatement technology, such as constituents that
approach limits of solubility for scrubbing media or constituents that approach the limits of
adsorptivity for adsorption systems. The general concept behind the use of the worst-case
conditions is to ensure that control devices will be able to achieve the required control over a
range of conditions. Having one compliance demonstration cover three standards also facilitates
consistent operating parameter monitoring, simplifying a consolidation effort.
D. Monitoring Requirements
Monitoring requirements for all three standards have many similarities. Each standard
requires monitoring of devices that control HAP emissions of less than 1 ton per year of
emissions and continuous (15-minute) monitoring of devices controlling HAP emissions of
greater than 1 ton per year. Monitoring consists of either parameter monitoring that is linked to
the initial compliance demonstration or direct monitoring of outlet concentration using
continuous emission monitors. A comparison of monitoring and inspection requirements in
subparts GGG, MMM, and FFFF is presented in Table 5.
11
-------
Table 5. Comparison of Monitoring Requirements in Subparts GGG, MMM, and FFFF
Parameter
Monitoring required if
APCD has inlet HAP
load 1 tpy and is used
to comply with any
standard except the
alternative standard
Scrubber/absorber
Condenser
Requirements
Subpart GGG
(PhRMA MACT)
Daily verification
[§63.1258(b)(l)(i>]
Continuous monitoring as
described below for specific
types of APCD
Continuous monitoring of
liquid flow or pressure
drop
Monitoring once/day of
scrubber effluent pH if
caustic is used to remove
acid emissions
[§63.1258(b)(l)(ii)]
Continuously monitor outlet
gas temperature
[§63.1258(b)(l)(iii)]
Subpart MMM
(PAI MACT)
Same as subpart GGG
[§63.1366(b)(l)(i>]
Same as subpart GGG
Same as subpart GGG
[§63.1366(b)(l)(ii>]
Same as subpart GGG
[§63.1366(b)(l)(iii)]
Subpart FFFF
(MON)
Same as subpart GGG, but
only allowed if at least
some of the emissions
controlled are from batch
process vents
[§63.2460(c)(5)]
Same as subpart GGG
For most halogen scrubbers:
Continuous monitoring of
scrubber inlet liquid flow
Measure or determine
inlet gas flow rate
Continuous monitoring of
pH or caustic strength of
the scrubber effluent
[§§63.994(c) and
63.2450(k)(3)]
For most absorbers:
Continuously monitor
liquid temperature and
specific gravity
Continuously monitor
organic concentration if
specific gravity meets
conditions specified in the
rule
[§§63.990(c)and63.993(c)]
If used to control emissions
from wastewater, request
approval of alternative
parameters [§63.143(e)(3)]
Continuously monitor
temperature of condenser
outlet (product side)
[§§63.990(c), 63.993(c),
and63.143(e)(l)]
12
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Table 5. Comparison of Monitoring Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Regenerative carbon
adsorber
Nonregenerative
carbon adsorber
Flares
Thermal incinerator
Catalytic incinerator
Requirements
Subpart GGG
(PhRMA MACT)
Monitor regeneration
cycle characteristics
(regeneration frequency,
temperature to which bed
is heated during
regeneration, temperature
to which bed is cooled
within 15 minutes of end
of cooling cycle, and
regeneration stream flow)
Annual check for bed
poisoning
[§63.1258(b)(l)(iv)]
Monitor time interval
between replacement based
on conditions anticipated
under worst-case conditions
[§63.1258(b)(l)(v)]
Continuously monitor for
presence of pilot flame
[§63.1258(b)(l)(vi>]
Continuously monitor
temperature of gases exiting
the combustion chamber
[§63.1258(b)(l)(vii)]
Continuously monitor
temperature of gas stream
immediately before and
after the catalyst bed, and
determine the temperature
difference
[§63.1258(b)(l)(viii)]
Subpart MMM
(PAI MACT)
Same as subpart GGG
[§63.1366(b)(l)(iv)]
Same as subpart GGG
[§63.1366(b)(l)(v>]
Same as subpart GGG
[§63.1366(b)(l)(vi)]
Same as subpart GGG
[§63.1366(b)(l)(vii)]
Same as subpart GGG
[§63.1366(b)(l)(viii)]
Subpart FFFF
(MON)
For each regeneration cycle:
Monitor total regeneration
stream mass or volumetric
flow
Monitor carbon bed
temperature after each
regeneration and within
15 minutes of the end of
each cooling cycle
No check for bed
poisoning
[§§63.990(c), 63.993(c),
and63.143(e)(l)]
For applications subject to
subpart SS, request
approval of planned
monitoring [§63.993(c)(4)
or §63.995(c)]
If used to control
emissions from
wastewater, same as
subpart GGG or monitor
organic concentration
[§63.143(e)(l)]
Same as subpart GGG
[§§63.987(c) and
63.143(e)(l)]
Continuously monitor
temperature immediately
downstream of the firebox
[§§63.988(c)(l) and
63.143(e)(l)]
Continuously monitor
temperature immediately
before and after the catalyst
bed, or monitor before the
bed and check catalyst
activity annually
[§§63.988(c)(2),
63.2450(k)(4), and
63.143(e)(l)]
13
-------
Table 5. Comparison of Monitoring Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Process heaters and
boilers where vent
gases are not
introduced with the
primary fuel or the
design heat input
capacity is >44 MW
Continuously monitor
temperature of gases exiting
the combustion chamber
[§63.1258(b)(l)(ix)]
Same as subpart GGG
[§63.1366(b)(l)(ix>]
Same as subpart GGG
[§§63.988(c)(3) and
63.143(e)(l)]
Required accuracy of
temperature monitoring
devices
For condensers and
carbon adsorbers, must be
accurate to within ±2
percent of the temperature
measured in degrees
Celsius or ±2.5°C,
whichever is greater
[§63.1258(b)(l)(iii)and
(iv)]
For combustion devices,
must be accurate to within
±0.75 percent of the
temperature measured in
degrees Celsius or±2.5°C,
whichever is greater
[§63.1258(b)(l)(vii)
through (ix)]
Same as subpart GGG
[§63.1366(b)(l)(vii)
through (ix)]
If monitoring a control
device used for any
emissions other than from
wastewater, must have
minimum accuracy of ±1
percent of the temperature
being monitored
expressed in degrees
Celsius or ±1.2°C,
whichever is greater
[§63.981]
If monitoring a control
device used with
wastewater emissions,
must have a minimum
accuracy of ±1 percent of
the temperature being
monitored expressed in
degrees Celsius or ±0.5°C,
whichever is greater
[§63.111]
Required accuracy of
flow monitoring
devices
For a scrubber, device
must be certified by the
manufacturer to be
accurate within ±10
percent of the design
scrubber liquid flow rate
[§63.1258(b)(l)(ii)]
For a carbon adsorber,
device must be capable of
recording the total
regeneration stream flow
to within ±10 percent of
the established value (i.e.,
accurate to within ±10
percent of the reading)
[§63.1258(b)(l)(iv)]
Same as subpart GGG
[§63.1366(b)(l)(ii)and
(iv)]
None specified for
scrubbers
For a carbon adsorber,
same as subpart GGG
[§§63.990(c)(2),
63.993(c)(3), and Table
13 to subpart G]
14
-------
Table 5. Comparison of Monitoring Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Required accuracy of
pressure drop
monitoring devices
Required accuracy of
pH monitoring devices
Required accuracy of
specific gravity
monitoring device
Parameter monitoring
calibration
requirements
Centralized combustion
control device
Fabric filter
Data averaging period
Requirements
Subpart GGG
(PhRMA MACT)
For a scrubber, must be
certified by the
manufacturer to be accurate
to within a gage pressure of
±10 percent of the
maximum pressure drop
measured
[§63.1258(b)(l)(ii)]
None specified
None specified
Annually
[§63.1258(b)(l)(ii),(iii),
(iv), (vii), (viii), and (ix)]
Monitor as described
above for the specific type
of combustion device
For periods of planned
routine maintenance of the
CCCD, monitor condenser
as described above and
monitor pH of scrubber
effluent once a day
[§63.1258(1)]
Not applicable
Daily or operating block
Exclude readings taken
during periods of no gas
flow
[§63.1258(b)(2)]
Subpart MMM
(PAI MACT)
Same as subpart GGG
[§63.1366(b)(l)(ii)]
Same as subpart GGG
Same as subpart GGG
Same as subpart GGG
[§63.1366(b)(l)(ii),
(iii), (iv), (vii), (viii),
and (ix)]
Not applicable
Use bag leak detection
system as specified in
the rule
[§63.1366(b)(l)(xi)]
Same as subpart GGG
[§63.1366(b)(2)]
Subpart FFFF
(MON)
None specified
Same as subpart GGG
Must have a minimum
accuracy of ±0.02 specific
gravity units (§§63.111 and
63.981)
Calibrate according to
manufacturers
specifications or other
written procedures that
assure accurate operation
(§§63.143(g)and
63.996(c)(l))
Not applicable
Not applicable for existing
sources
Same as subpart GGG
[§§63.998(b)(3)and
63.2460(c)(4)and(7)]
15
-------
Table 5. Comparison of Monitoring Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Flow indicators (for gas
stream through the
APCD)
Required if flow to control
device could be intermittent
[§63.1258(b)(2)(iii)]
Same as subpart GGG
[§63.1366(b)(2)(iii)]
Same as subpart GGG
[§63.2460(c)(7)]
Procedures for setting
APCD parameter limits
(i.e., operating limits)
If initial compliance
demonstration consists of a
performance test:
Base operating limit on
average of values from 3
test runs
May supplement test data
with engineering
assessment and
manufacturer's
recommendations
May set separate levels
for different operating
conditions (i.e., for APCD
that controls emissions
from batch process vents)
Otherwise set operating
limits as part of the design
evaluation
[§63.1258(b)(3)(i) through
(iii)]
Same as subpart GGG
[§63.1366(b)(3)(i)
through (iii)]
Same as subpart GGG
[§§63.999(b)(3)and
63.2460(c)(3)]
16
-------
Table 5. Comparison of Monitoring Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Alternative standard
TOC CEMS must meet PS
8, 9, or 15 of appendix B
of part 60
HC1 CEMS must meet PS
15, or you must prepare
and submit a monitoring
plan for approval
Parameter monitoring
instead of CEMS allowed
for scrubbers used to
control HC1 generated in
combustion APCDs
Correct concentrations at
outlet of control devices
for supplemental gases, or
implement optional
provisions noted below
For combustion device,
the option is to maintain
temperature and residence
time as specified in the
rule
For noncombustion
device, the option is to
implement provisions for
"dense gas systems," if
applicable
[§63.1258(b)(5)]
Same as subpart GGG
except:
Rule does not include
specifications for
HC1/C12 CEMS
Must use CEMS to
monitor HC1/C12 out
of scrubber after
combustion device
(i.e., no parameter
monitoring option)
Must correct
concentrations for
supplemental gases
when using
noncombustion
controls (i.e., no
provision for "dense
gas systems")
[§63.1366(b)(5)]
Same as subpart GGG
except:
For any CEMS meeting
PS 8, you must also
comply with appendix F,
procedure lof40CFR
part 60
Concentrations must be
corrected for supplemental
gases (i.e., the options for
combustion devices and
dense gas systems in
§63.1258(b)(5)(ii)arenot
included) [§63.2505(b)]
Equipment leak
monitoring
LDAR monitoring
provisions are specified in
§63.1255
LDAR monitoring
provisions are specified
in §63.1363 (same as
§63.1255)
Table 6 to subpart FFFF
references LDAR
monitoring provisions in
40 CFR part 63 subpart
UU or 40 CFR part 65
subpart F for processes
with any continuous
process vents
Table 6 to subpart FFFF
references LDAR
monitoring provisions in
40 CFR part 63 subpart
TT or UU or 40 CFR part
65 subpart F for processes
without any continuous
process vents
17
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Table 5. Comparison of Monitoring Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Floating roofs for
storage tanks
Rule references the
inspection and measurement
requirements in §63.120 of
theHON
[§63.1257(c)(3)]
Same as subpart GGG
[§63.1366(d)(3)]
Table 4 to subpart FFFF
references the inspection
requirements in 40 CFR part
63, subpart WW (slight
differences from subpart
GGG, but substantively the
same)
Biological treatment
units
Monitor TSS, BOD, and
biomass concentration at
frequency approved by
permitting authority, and
use methods approved by
permitting authority
[§63.1258(g)(2)]
Request approval to
monitor appropriate
parameters that
demonstrate proper
operation. Describe the
parameter(s), planned
methods, and the
frequency of
monitoring as part of
the request
[§63.143(c>]
Same as subpart MMM
[Table 7 to subpart FFFF
references §63.143(c)]
Nonbiological
treatment units
Request approval to monitor
appropriate parameters that
demonstrate proper
operation
[§63.1258(g)(3)]
Same as subpart GGG,
except must
continuously monitor
steam flow rate,
wastewater feed
temperature, and
wastewater mass
flowrate for steam
strippers [§63.143(b)
and (d)]
Same as subpart MMM
[Table 7 to subpart FFFF
references §63.143(b) and
(d)]
Waste management
unit inspections for
improper work
practices and control
equipment failures
Conduct initial and
semiannual visual
inspections, measure
primary seal gaps once
every 5 years (or annually,
if there are no secondary
seals), and measure
secondary seal gaps initially
and annually
[§63.1258(g)(l)]
Same as subpart GGG
[§§63.143(a)and
63.148(b)(3)(ii)]
Same as subpart MMM
[Table 7 to subpart FFFF
references §§63.143(a) and
63.148(b)(3)(ii)]
Bypass lines around
APCDs
Continuously monitor
using a flow indicator, or
Install car-seal, and
visually inspect monthly
[§63.1252(b>]
Same as subpart GGG
[§63.1362©]
Same as subpart GGG
[§63.2450(d) and (e)
reference §63.983(a)(3), and
Table 7 to subpart FFFF
references §63.148(f)]
18
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Table 5. Comparison of Monitoring Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Closed vent system and
vapor suppression
equipment leak
inspections
Inspections are consistent
with the HON:
Initial M21 inspections for
all
Annual visual inspections
for hard piping
Annual M21 and visual
inspections for ductwork
The rule specifies M21
detection instrument
performance criteria,
calibration requirements,
leak definitions, repair
requirements, delay of
repair, unsafe-to-inspect
and difficult-to-inspect
requirements
[§63.1258(h)]
Same as subpart GGG
except:
Does not specifically
state that background
levels shall be
determined as
specified in M21
Does not include a
separate repair
schedule for leaks in
vapor collection
systems for transfer
operations because
the rule does not
apply to transfer
operations
Limits requirement to
inspect unsafe-to-
inspect equipment to
no more than once
per year
[§63.1366(h)]
Table 7 to subpart FFFF
references inspection
requirements in §63.148
of the HON for closed-
vent systems and vapor
suppression equipment
used with wastewater
systems (same
requirements as in subpart
GGG)
§63.2450(d) and (e)
reference inspection
requirements in §63.983
of subpart SS for closed-
vent systems.
Requirements are the
same as in subpart GGG
except
Specifies additional
calibration gas for
instruments that have
multiple calibration
scales
Visual indications of a
leak are not a leak if
M21 is also used and
reading is <500 PPM
Heat exchange systems
Monitor as specified in
§63.104 of the HON except:
Monitoring may be no
less frequent than
quarterly
If CGMP requirements of
21 CFR part 211 are met,
may elect to use physical
integrity of the reactor as
surrogate indicator of heat
exchanger leaks around
the reactor
[§63.1252(c)]
Monitor as specified in
§63.104 of the HON
[§63.1362(f) references
§63.104]
Same as subpart MMM
[Table 10 to subpart FFFF
references §63.104]
19
-------
Table 5. Comparison of Monitoring Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Exceedances
An exceedance means
Averaged parameter
level above maximum
or below minimum
operating parameter
levels
Loss of all pilot flames
in a flare
The rule specifies
violations associated with
various exceedances
[§63.1258(b)(6)and(8)]
Same as subpart GGG
except exceedances
also include
Each operating day or
block for which the
time interval before
replacement of a non-
regenerative carbon
adsorber exceeds the
interval set during
initial compliance
Each instance when a
response to a bag leak
detector alarm within
1 hour occurs
[§63.1366(b)(6)and
(8)]
Subpart FFFF uses the
term "deviation," which is
defined as
Any instance when the
source fails to meet any
obligation established in
the rule such as any
emission limit,
operating limit, or work
practice standard,
including during periods
of SSM
Any instance when the
source fails to meet any
term or condition that is
adopted to implement an
applicable requirement
in the rule and that is
included in the
operating permit
As part of the referenced
alternative recordkeeping
requirements in subpart
SS, the term "excursion"
has the same meaning as
exceedance in subpart
GGG, except it does not
apply to flare pilot flames
[§63.998(b)(5)(ii)and(6)]
Rule does not specify
violations
Excursions
Lack of valid monitoring
data for > 1 hr when
control device operates <4
hr/d
Lack of valid monitoring
data for >25% of control
device operating hours if
the control devices
operates >4 hr/d
Data for each 15-minute
period in an hour are
needed to have a valid
hour of data
[§63.1258(b)(7)]
Same as subpart GGG
[§63.1366(b)(7>]
Same as subpart GGG
except
Two data points in an
hour are sufficient to have
a valid hour of data for
CEMS when the lack of
data is due to calibration,
QA, or maintenance
[§63.999(c)(6>]
20
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E. Reporting and Recordkeeping
Comparisons of recordkeeping and reporting requirements are summarized in Tables 6
and 7, respectively.
Table 6. Comparison of Recordkeeping Requirements in Subparts GGG,
MMM, and FFFF
Parameter
Recordkeeping
requirements in
§63.10(b)and
(c) of the
General
Provisions
SSMP
Recordkeeping requirements
Subpart GGG
(PhRMA MACT)
Table 1 to subpart GGG
specifies that
§63.10(b)(l), (b)(3), and
(c) apply, but
§63.10(b)(2)doesnot.
However, all of the
provisions in
§63.10(b)(2)are
included in §63. 1259(a)
and (b) except
Records associated
with a waiver of
recordkeeping
requirements as
specified in
§63.10(b)(2)(xii)
Records of emission
levels associated with
obtaining permission
to use an alternative to
aRATAforCEMSas
specified in
§63.10(b)(2)(xiii)
Records of
adjustments to CMS
Prepare, revise, and
retain as specified in
§63.6(e)(3)
Subpart MMM
(PAI MACT)
Same as subpart
GGG
[Table 1 to subpart
MMM and
§63.1367(a)and(b)]
Same as subpart
GGG
Subpart FFFF
(MON)
Table 8 to subpart FFFF specifies that
§63.10(b)(l) and (b)(3) apply, and parts of
§63. 10(b)(2) and (c) apply. Other requirements
are specified in subpart SS. Differences
relative to the General Provisions are
Records of occurrence and duration of each
SSM of process equipment, or each
malfunction of APCD or monitoring
equipment, required only if excess emissions
occur (§63.998(c)(l)(ii)(D) and (d)(3)(i))
Records of actions taken during SSM
required only if excess emissions occur
(§63.998(c)(l)(ii)(E) and (d)(3)(ii))
For SSM of CPMS, must keep additional
record that no excess emissions occurred, if
applicable (§63. 998(c)(l)(ii)(G))
Keep records of the duration of each period of
excess emissions rather than the start and end
times (i.e., §63.998(c)(l)(ii) and (d)(3)(i) vs.
§63 . 10(c)(7) and (8)), except when using a
CEMS to comply (§63.2525(h))
Records of only certain adjustments to CPMS
are specified in §63.998(c)(l)(ii)(B) (vs
§63.10(b)(2)(xi))
Records of CMS out-of-control periods apply
only to CEMS (no requirement comparable to
§63.10(b)(2)(vi) in subpart SS)
Records of nature and cause of CMS
malfunction, corrective action or preventive
measures adopted, nature of repairs, and
procedures that are part of a QC program
apply only to CEMS (no provision
comparable to §63.10(c)(10, 11, 12, and 14)
in subpart SS)
Same as subpart GGG except:
Group 2 emission points do not need to be
included
For equipment leaks, the SSMP must address
control devices and optional for other
equipment
[§63.2525(j)]
21
-------
Table 6. Comparison of Recordkeeping Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Recordkeeping requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Measurement
of monitored
parameters for
control devices
and wastewater
treatment units
Keep records of each
CEMS or CPMS
measurement for
control devices and
each measurement of
approved parameters
for treatment units
[§63.1259(b)(l)]
Also keep any other
records of treatment
units required by the
Administrator
[§63.1258(g)(2)and
(3)]
Same as subpart
GGG
[§§63.1367(b)(l)
and63.147(b)(4),
(b)(5), and (d)]
For treatment units and control devices used
to control emissions from waste management
units, keep the continuous records of
monitored parameters (each value or 15-
minute averages) and the daily averages,
except keep records of all periods when the
pilot flame is absent for flares and
regeneration cycle records for carbon
adsorbers. Alternatively, may keep only
block hourly averages rather than the 15-
minute data if daily average is in compliance,
or may elect not to calculate average if all
data values are in compliance. Also keep any
other records required by the Administrator
for treatment units [§§63.147(b)(4), (b)(5),
and(d)and63.152(f)]
Follow subpart SS for other APCDs. Six
options:
(1) keep all continuous records and the
daily^lock average; or
(2) keep 15-minute values or averages and
daily^lock average; or
(3) if CPMS data are collected with
automated equipment, calculate hourly
averages and discard all but the most recent
three hours of valid raw data (if data collected
during CPMS breakdown and malfunction are
included) and keep daily average; or
(4) if all of the recorded values meet the
operating limit for a parameter during an
averaging period, then may keep a record of
this fact along with all of the individual
values without calculating a daily^lock
average; or
(5) retain only the daily/block average value
if various conditions are met; or
(6) keep no records if a period of 6 months
passes without an excursion (i.e., an
"exceedance" as defined in subpart GGG)
[§63.998(b)(l), (b) (3), (b)(5)(i), and
22
-------
Table 6. Comparison of Recordkeeping Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
(continued
from above)
Records related
to process vent
standards
Operating
scenarios
Recordkeeping requirements
Subpart GGG
(PhRMA MACT)
(continued from above)
If complying with the
percent reduction
standard, and some
APCDs achieve less than
93% control, then keep
records of
Standard batch
uncontrolled and
controlled emissions
Actual emissions/
batch
Record of whether the
batch was a standard
batch
[§63.1259(b)(5)(i>]
Keep copy of each
operating scenario
Keep a schedule or log
of operating scenarios,
updated each time a
new operating scenario
is put into operation
[§63.1259(b)(8)and(c)]
Subpart MMM
(PAI MACT)
(continued from
above)
For all processes,
keep records of
Initial calculation
of uncontrolled
and controlled
emissions per
batch (not
required if an
emissions profile
is not required)
Number of
batches/yr for
processes with
batch operations
Number of
operating hr/yr for
processes with
continuous
operations
[§63.1367(b)(6)(i),
(iv), (v), and (ix)]
Keep a schedule
or log of operating
scenarios, updated
each time a new
operating scenario
is put into
operation
No specific
requirement to
keep records of
operating
scenarios, but they
must be included
in the NOCS
[§§63.1367(b)(7)
and63.1368(f)(4)]
Subpart FFFF
(MON)
Keep records of the occurrence and cause
of periods of operation when the parameter
limits are exceeded [§63.998(c)(2)(iii) and
(3)(iii) and (d)(5)]
- Less comprehensive records required if the
control device is used only for equipment leak
emissions [§63.998(d)(4)]
If complying with the percent reduction
standard, and some APCDs achieve less than
98% control, then keep records of:
Whether each batch was a standard batch
The estimated uncontrolled and controlled
emissions for each nonstandard batch
[§63.2525(d)]
Same as subpart GGG
[§63.2525(b)and(c)]
23
-------
Table 6. Comparison of Recordkeeping Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Inspection of
floating roofs
for storage
tanks
Vapor
balancing for
storage tanks
Planned routine
maintenance
Wastewater
stream
characteristics
Recordkeeping requirements
Subpart GGG
(PhRMA MACT)
Maintain records of
floating roof inspections
and seal gap
measurements as
specified in §63.123(c)
through (e)
[§63.1259(b)(ll)]
Maintain records of
The DOT certification
The pressure relief
vent setting
Leak detection results
[§63.1259(b)(12)]
Keep records (date and
time) of periods of
planned routine
maintenance for
Storage tanks that vent
emissions to APCDs
Centralized
combustion control
devices (CCCDs)
[§63.1259(b)(10)]
Keep record of partially
soluble and soluble HAP
concentrations in
wastewater per POD or
process [§63.1259(b)(6)]
Subpart MMM
(PAI MACT)
Same as subpart
GGG
[§63.1367(b)(l)]
Same as subpart
GGG
[§63.1367(b)(8>]
Same as subpart
GGG for APCD
used to control
emissions from
storage tanks
CCCD provisions
are not included
[§63.1367(b)(6)
(viii)]
Keep records of the
subpart G Table 9
HAP concentrations
and wastewater
stream flow rate per
POD and process
[§63.1367(b)(6)(ii)]
Subpart FFFF
(MON)
§63.1065 of subpart WW is more specific
about how to document results of floating
roof inspection than §63. 123 (c) through (e)
Records of seal gap measurements are the
same as for subpart GGG
Must keep record of vessel dimensions,
capacity, and type of liquid stored (although
not a specific recordkeeping requirement in
subpart GGG, this information is needed to
perform the initial compliance demonstration
and would be documented in the NOCS)
Must keep records of floating roof landings
Must keep documentation associated with use
of the extension provisions (not in subpart
GGG because it does not reference
§63.123(g))
Same as subpart GGG
[§63.2525(a) references the applicable
recordkeeping requirements in subpart
GGG-i.e., requirements in §63.1259(b)(12)]
Same as subpart GGG for APCD used to
control emissions from storage tanks, except
also must record a description of the type of
maintenance performed [§63.998(d)(2)(ii)]
CCCD provisions are not included
Except as noted below for Group 2 streams, no
specific recordkeeping requirement. However,
Table 9 HAP concentrations and flow rates
must be included in the NOCS
24
-------
Table 6. Comparison of Recordkeeping Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Use of process
knowledge to
determine
Group 2 status
of a wastewater
stream
Notices sent
with
wastewater to
offsite
treatment
operators
Maintenance
wastewater
plan
Waste
management
unit inspections
for improper
work practices
and control
equipment
failures
Recordkeeping requirements
Subpart GGG
(PhRMA MACT)
Rule uses the term "not
affected" rather than
"Group 2." The
procedures used to
determine which
wastewater streams are
not affected must be
included in the NOCS
[§63.1260(f)(l>]
Keep record of the
notices
[§63.1259(g)]
Procedures to develop,
modify, update, and
implement plan are
consistent with
requirements in §63.105
[§63.1256(a)(4)]
Keep record
documenting that
required inspections
were conducted
[§63.1259(i)(l)]
Subpart MMM
(PAI MACT)
Keep record of
Group 2
determinations that
are based on process
knowledge
[§63.1362(d)
references
§63.147(f)]
Same as subpart
GGG
[§63.1362(d)
references
§63.147(a)]
No requirement to
develop a plan for
maintenance
wastewater
(However, any
individual discharge
of maintenance
wastewater that
contains at least 5.3
Mg of HAP listed
on Table 9 of
subpart G must be
managed and treated
as Group 1
wastewater)
Same as subpart
GGG
[§63.1362(d)
references
§63.147(b)(l)]
Subpart FFFF
(MON)
Same as subpart MMM
[Table 7 to subpart FFFF references §63.147(f)]
Same as subpart MMM
[Table 7 to subpart FFFF references
§63.147(a)]
Same as subpart GGG
[Table 7 to subpart FFFF references §63. 105]
Same as subpart MMM
[Table 7 to subpart FFFF references
§63.147(b)(l)]
25
-------
Table 6. Comparison of Recordkeeping Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Delay of repair
provisions for
emission
suppression
control
equipment due
to
unavailability
of parts
Operating
extension for
wastewater
tanks after
determining
floating roof is
unsafe to
inspect or
inspection
reveals control
equipment
failure
Seal gap
measurements
for floating
roofs on
wastewater
tanks
Location at
which vent
stream entering
boiler or
process heater
that is used to
control
emissions from
waste
management
units
Recordkeeping requirements
Subpart GGG
(PhRMA MACT)
Keep records
documenting decision to
use the provision
[§63.1259(f)]
Keep records
documenting decision to
use an extension
[§63.1259(h)]
Keep records of seal gap
measurements
[§63.1259(i)(3)]
No record required
Subpart MMM
(PAI MACT)
Same as subpart
GGG
[§63.1362(d)
references
§63.147(b)(7)]
Same as subpart
GGG
[§63.1362(d)
references
§63.147(b)(6)]
Same as subpart
GGG
[§63.1362(d)
references
§63.147(b)(3)]
Keep a record of
any changes in the
location at which
the vent stream is
introduced into the
flame zone
[§63.1362(d)
references
§63.147(c)]
Subpart FFFF
(MON)
Same as subpart MMM
[Table 7 to subpart FFFF references
§63.147(b)(7)]
Same as subpart MMM
[Table 7 to subpart FFFF references
§63.147(b)(6)]
Same as subpart MMM
[Table 7 to subpart FFFF references
§63.147(b)(3)]
Same as subpart MMM
[Table 7 to subpart FFFF references
§63.147(c)]
26
-------
Table 6. Comparison of Recordkeeping Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Visual and
M21
inspections of
closed-vent
systems and
inspections of
vapor
suppression
equipment for
waste
management
units
Inspections of
unsafe-to-
inspect and
difficult-to-
inspect closed-
vent systems
and emission
suppression
systems
Inspections of
control devices
used to control
emissions from
waste
management
units
Bypass lines
around control
deices
Heat exchange
systems
Recordkeeping requirements
Subpart GGG
(PhRMA MACT)
Keep record of various
information specified
in the rule if a leak is
detected during the
inspection
[§63.1259(i)(7)]
Document date of
inspection and state
findings if no leaks
were detected
[§63.1259(i)(8)and
(9)]
Keep records identifying
the subject equipment
and written plans for
inspecting the equipment
[§63.1259(i)(4)and(5)]
Keep records
documenting that
required inspections
were conducted
[§63.1259(i)(2)]
Keep hourly records of
whether the flow
indicator was operating
and any diversion was
detected, or keep record
of monthly visual
inspection of the seal
mechanism
[§63.1259(i)(6)]
No recordkeeping
requirements specifically
listed in §63. 1259, but
§63. 1252(c) specifies
that all of §63. 104 is to
be followed
Subpart MMM
(PAI MACT)
Same as subpart
GGG
[§63.1367(f)(4)
through (6)]
Same as subpart
GGG
[§63.1367(f)(l)and
(2)]
Same as subpart
GGG
[§63.1362(d)
references
§63.147(b)(2)]
Same as subpart
GGG
[§63.1367(f)(3)]
Comply with
requirements in
§63.104
[§63.1367(e)]
Subpart FFFF
(MON)
Same as subpart GGG except
The following records are not required for
closed vent systems that do not convey any
wastewater emissions (§63.998(d)(l)(iii)):
Name or other identification of individual
who decided a repair could not be effected
without shutdown
Expected date of successful repair if leak is
not repaired within 15 calendar days
Dates of shutdowns that occur while the
equipment is unrepaired
Same as subpart GGG
[§63.998(d)(l)(i) for closed vent systems and
§63.148(i)(l) and (2) for both closed-vent
systems and emission suppression equipment]
Same as subpart MMM
[Table 7 top subpart FFFF references
§63.147(b)(2)]
Same as subpart GGG
[(§63.998(d)(l)(ii) and Table 7 references
§63.148(i)(3)]
Same as subpart MMM
[Table 10 to subpart FFFF references §63.104]
27
-------
Table 6. Comparison of Recordkeeping Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
LDAR program
for equipment
leaks
Process unit
groups (PUG)
CEMS
deviations
Recordkeeping requirements
Subpart GGG
(PhRMA MACT)
Records as specified in
§63.1255
Not applicable
Section 63. 10(c)(8)
referenced from
§63.1259(a)(4)
Subpart MMM
(PAI MACT)
Records as specified
in§63.1363(g)
(same as subpart
GGG)
Keep records of
The process units
in the PUG
The operating
time for each
process unit in the
PUG
Each
redetermination of
the primary
product of the
PUG
[§63.1367(b)(9>]
Section 63. 10(c)(8)
referenced from
§63.1367(a)(4)
Subpart FFFF
(MON)
Records as specified in 40 CFR subpart TT or
subpart UU [§63. 2525(a)]
Differences in subpart UU relative to subpart
GGG include
Differences in records for leak repairs
(§63.1024(f)vs§63.1255(g)(4))
For valve reassignments between
subgroups, must keep record of last
monitoring result prior to reassignment
Must record the start and end dates of each
monitoring period if complying with the
skip monitoring provisions for connectors
QIP records
Must keep records for unsafe -to -repair
connectors
Slight differences in equipment
identification listing requirements
Differences in subpart TT relative to subpart
GGG include
Valve subgrouping is not allowed, so no
records for subgrouping
No instrument monitoring for connectors,
so no records of start and end date of
monitoring period
No pressure testing alternative means of
emission limitation
Keep the following records:
Descriptions of all of the process units in the
initial PUG
Rationale for including each process unit in
the initial PUG
Calculations used to determine the primary
product of the initial PUG
Descriptions of, and rationale for adding,
process units to the PUG after the creation
date
The calculation of each primary product
redetermination
[§63.2525(i)]
Keep records of the date and time that each
CEMS deviation started and stopped, and note
whether or not the deviation occurred during a
period of SSM
[§63.2525(h)]
28
-------
Table 7. Comparison of Reporting Requirements in Subparts GGG,
MMM, and FFFF
Parameter
Reporting requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Initial
Notification
Per §63.9(b) or (d)
Same as subpart GGG
Same as subpart GGG
Application for
approval of
construction or
reconstruction
Per §63.5(b)(3) and (d)
Same as subpart GGG
Same as subpart GGG
Notification of
CMS
performance
evaluation
Notify date of performance
evaluation per §63.8(e)(2)
Same as subpart GGG,
except the performance
evaluation is only required
for CEMS that are used to
comply with the alternative
standard
Same as subpart GGG
SSM reports
Submit as specified in
§63.10(d)(5), except use same
schedule as for periodic
reports
[§63.1260(1)]
Same as subpart GGG.
[§63.1368(1)]
Include as part of the
compliance reports
No immediate SSM report
Report information only for
periods of excess emissions
Precompliance
Report
Submit 3 months prior to
compliance date for approval
of
(1) Requests to use alternative
monitoring or parameters
(2) Description of per batch
demonstrations for small
control devices
(3) Description of test
conditions for parameters
set using supplemental
engineering assessment
(4) P2 demonstration
summary
(5) Description of engineering
assessment to calculate
uncontrolled emissions
(6) Process simulation data
for determination of
annual average concentra-
tion of wastewater
(7) Bench scale or pilot scale
data determination of
annual average
concentration of
wastewater
[§63.1260(e>]
Same as GGG with the
following exceptions:
No precompliance report
for process simulation,
bench scale or pilot scale
determinations for
wastewater concentrations
Operation and maintenance
plan required for bag leak
detectors
Same as MMM except also
requires identification and
discussion of control measures
for streams with energetics
and peroxides that are not
controlled to levels of
standard because of undue
safety hazards
29
-------
Table 7. Comparison of Reporting Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Reporting requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Notification of
Compliance
Status
Submitted 150 days after the
compliance date to include
Applicability determinations
Emission estimates
Information used to
demonstrate compliance
(e.g., tests, design
evaluations, emission
profiles, and calculations)
Lists of operating scenarios
Description of worst-case
operating and/or testing
conditions for control
devices
Identification of emission
points subject to overlapping
requirements and the rule to
be complied with
Information regarding
planned routine maintenance
ofCCCDs
Information about
equipment leak components
[§§63.1255(h)(2)and
631260(f)]
Same as GGG, except
Requires the operating
scenarios instead of a
listing of them
Requires that streams
routed to RCRA devices be
identified
Requires identification of
percent of PAI unit
production for use as a PAI
Requires records of initial
process units used to create
process unit groups
Information about CCCDs
is not applicable
[§§63.1363(h)(2)and
63.1368(f)]
Same as GGG, except
Requires the operating
scenarios instead of a listing
of them
Requires records of process
units used to create a PUG
and calculation of initial
primary product of PUG
Requires identification of
storage tanks subject to the
vapor balancing alternative
Information about CCCDs is
not applicable
[§63.2520(d)]
Periodic reports (Compliance reports)
Schedule of
reports
Generally, semi-annual
reporting periods
Quarterly reporting required
after certain exceedances
and if a new operating
scenario is implemented
First reporting period is for
the six months beginning on
the NOCS due date
Reports must be submitted
no later than 60 days after
the end of the reporting
period
[§63.1260(g)(l)]
Same as subpart GGG except
Implementing a new
operating scenario does not
trigger quarterly reporting
[§63.1368(g)(l)]
Always semi-annual
reporting periods (no
quarterly reporting)
First reporting period begins
on the compliance date and
extends to June 30 or
December 31, whichever is
later (thus the first reporting
period is longer than 6
months)
Section 63.10(e)(3) does not
apply because reporting
requirements are specified in
§63.2520
[§63.2520(b)andTable8to
subpart FFFF]
30
-------
Table 7. Comparison of Reporting Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Reporting requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Information to
submit associated
with CMS
Submit information
specified in
§63.10(e)(3)(vi)(A) through
(M), as applicable
If excess emissions,
exceedances, and excursions
exceed 1% of total operating
time, or total CMS
downtime exceeds 5% of
total operating time, submit
Monitoring data,
including daily average,
for days when the average
is out of compliance
Operating logs and
operating scenarios for the
days of noncompliance
Duration of excursions
Information specified in
§63.10(c)(5) through (13)
for CMS
To the extent applicable,
state that the reporting
period had no excess
emissions, exceedances,
excursions, or periods in
which CMS were
inoperative, out-of-control,
repaired, or adjusted
[§63.1260(g)(2)(i)and(ii)]
Same as subpart GGG
[§63.1368(g)(2)(i)and(ii)]
Several differences relative to
subpart GGG:
Section 63. 10(e)(3) does not
apply
Reporting of data is required
for all periods of deviations,
not limited to reporting
periods when the total
duration of excess
emissions, exceedances, and
excursions exceed the
threshold specified in
§63.10(e)(3)(vii)and(viii)
Must identify cause of all
deviations, not just
malfunctions
[§63.2520(e)(5)(ii)(B) and
Operating logs not required
for deviations from work
practice standards for
equipment leaks
[§63.2520(e)(5)(ii)(C)]
Do not submit operating
scenarios for days with
deviations
Submit only the operating
day /block average values for
the days with any deviations
that occurs when using a
CMS
[§63.2520(e)(5)(iii)(L)]
No need to categorize
periods of CMS downtime
by the cause of the
downtime separately from
other deviations
[§63.2520(e)(5)(iii)(D)and
(E)]
Do not describe changes in
CMS, process, or controls,
except as they are
considered changes to
operating scenarios
[§63.2520(e)(10)]
31
-------
Table 7. Comparison of Reporting Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Reporting requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Operating
scenarios
Submit each new operating
scenario implemented during
the reporting period
[§63.1260(g)(2)(vii)]
New operating scenarios
must be submitted in the
notification of process
change
[§63.1368(h)(l)]
Same as subpart GGG
[§63.2520(e)(7)]
PM HAP controls
Not applicable
Update corrective action plan
for the fabric filter
[§63.1368(g)(2)(viii)]
Not applicable for existing
sources
Bypass lines
Submit records of periods
when gas streams were
diverted to the bypass, the seal
was broken, the bypass line
valve was changed, or the key
to unlock the bypass valve
was checked out
[§63.1260(g)(2)(iv)]
Same as subpart GGG
[§63.1368(g)(2)(iii)]
Same as subpart GGG
(§§63.146(e)(l), 63.148(j)(2)
and (3), and63.999(c)(2)(ii)
and (iii))
Storage tanks
If complying by using an
APCD, submit records of
periods of planned routine
maintenance
If complying by using a
floating roof, submit records
as specified in §63.122(d)
through (f)
[§63.1259(g)(2)(vi)and(viii)]
If complying by using an
APCD, submit records of
actual periods of planned
routine maintenance and
anticipated periods of
planned routine
maintenance in the next
reporting period
If complying by using a
floating roof, same as
subpart GGG
[§63.1368(g)(2)(v)and(xii)]
If complying by using an
APCD, submit records of
periods of planned routine
maintenance (specified in
Table 6 above), the total
number of hours that
required control was not
met, and a description
planned routine maintenance
for the next reporting period
(i.e., the activity, frequency,
and length of time)
[§63.999(c)(4)]
If complying by using a
floating roof, submit
Inspection record when
inspection failures occur
(as noted in Table 6,
records are slightly
different than for subpart
GGG; definition of
failures are basically
consistent)
Documentation to support
requests for extensions
[§63.1066(b)(2)and(4)]
32
-------
Table 7. Comparison of Reporting Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Reporting requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Waste
management units
and wastewater
treatment units
Administrator will specify
appropriate reporting for
treatment units
[§63.1258(g)(2)and(3)]
Submit results of
measurements that indicate
biological treatment unit is
out of compliance
[§63.146(d)(l>]
Submit monitoring results
for each operating day that
steam stripper is out of
compliance [§63.146(d)(2)]
For other treatment units,
the Administrator will
specify appropriate
reporting requirements
[§63.146(f)]
Report results of any
extension [§63.146(g)]
For each control equipment
failure identified during an
inspection, of waste
management units, include
description of the failure,
description of the nature of
the repair, and the date of
repair [§63.146(c)]
Same as subpart MMM
[Table 7 references §63.146]
33
-------
Table 7. Comparison of Reporting Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Reporting requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Equipment leaks
Submit records of the
number of leaking
components and the number
monitored
Submit records of leaking
components not repaired and
those that were determined
to be nonrepairable
Explanation of any delay of
repairs
Results of monitoring for
compressors designated to
operate with instrument
reading of less than 500 ppm
above background, all
pressure relief valve
monitoring, and all
monitoring of closed vent
systems that convey
equipment leak emissions
Submit records documenting
initiation of monthly
monitoring for pumps and
valves
Notification of a change in
monitoring for connectors
that have been opened or
had the seal broken
Various records for
equipment that is pressure
tested
Revisions to any items
reported in the NOCS, if the
method of compliance has
changed since the previous
report
[§63.1255(h)(3)]
Same as subpart GGG except
revisions to the information
submitted in the NOCS is not
limited to changes in the
method of compliance
[§63.1363(h)(3>]
Compliance with subpart
UU is the same as subpart
GGG except
Report valve subgrouping
information, if applicable
(§63.1039(b)(3))
QIP records
Compliance with subpart TT
requires submittal of only
Total number of valves,
pumps, and compressors
(in the initial report)
Number of leakers
Number not repaired
Explanation of delay of
repair
Dates of shutdown during
the reporting period
Revisions to any of the
information submitted in
previous reports (i.e.,
regarding the total number
of components)
34
-------
Table 7. Comparison of Reporting Requirements in Subparts GGG,
MMM, and FFFF (continued)
Parameter
Reporting requirements
Subpart GGG
(PhRMA MACT)
Subpart MMM
(PAI MACT)
Subpart FFFF
(MON)
Inspection of
closed vent
systems and
emission
suppression
equipment for
leaks
Submit recorded information
for each leak that is detected
[§63.1260(g)(2)(iii)]
Same as subpart GGG
[§63.1368(g)(2)(xi)]
Same as subpart GGG except
Do not need to submit
record of instrument and
operator identification for
closed vent systems that are
not used for wastewater
emissions
[§63.999(c)(2)(i)vs
§63.1480)(1)]
Process unit
groups
Not applicable
Submit records of process
units added to the PUG
Submit records of
redeterminations of the
primary product
[§63.1368(g)(2)(ix)and(x)]
Same as subpart MMM
[§63.2520(e)(8)]
Notification of Process Change
Documentation
after a change to
information
submitted in the
NOCS
The following information is
to be submitted quarterly or
with the periodic report
A brief description of the
change
A description of any
modifications to standard
procedures or quality
assurance procedures
Revisions to information
submitted in the NOCS
Information required by the
NOCS for changes
involving the addition of
equipment or processes
[§63.1260(h)(l)]
Same as subpart GGG
[§63.1368(h)(l)]
Essentially the same as
subpart GGG except
Submit with compliance
report
The information is required
only for changes that are not
within the scope of an
existing operating scenario
Language does not
specifically require
documentation of
modifications to standard
procedures or quality
assurance procedures
(because any such change is
a change to an operating
scenario, which also must be
reported in compliance
reports)
[§63.2520(e)(10)(i)]
Documentation to
submit 60 days
before a change
Any change in activity
covered by the
precompliance report
A change in status of a
control device from small to
large
[§63.1260(h)(2)]
Same as subpart GGG
[§63.1368(h)(2)]
Same as subpart GGG except
also identify any change of an
emission point from Group 2
to Group 1
[§63.2520(e)(10)(ii)]
35
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F. Summary of Specific Provisions for Overlapping Requirements
Each of the rules contains a specific section that describes options for complying with
only one rule when the same equipment is subject to more than one rule, including new source
performance standards (NSPS) as well as 40 CFR part 63 standards. These options are
particularly helpful for emissions sources such as leaking equipment components subject to Leak
Detection and Repair (LDAR). Having one LDAR program plantwide simplifies the compliance
approach. Other specific overlapping requirements address storage tanks and wastewater
treatment systems. These provisions are summarized in Table 8 and are also discussed below.
1. Consistency with NSPS for storage tanks in 40 CFR part 60, subpart Kb
Each of the three rules specifies that an owner or operator may comply with the
applicable part 63 standard in lieu of the NSPS in subpart Kb. Additionally, each rule requires
that the storage tank be assigned to a unit based on its primary storage use, eliminating the
possibility that a tank will be subject to multiple MACT standards.
2. Consistency with other MACT standards
As noted in Table 8, both subparts GGG and MMM (PhRMA and PAI MACTs) contain
identical language that provide an option to consolidate recordkeeping and reporting
requirements if the compliance requirements under the two rules are consistent. As noted in the
previous discussion, there is significant consistency in the requirements of the standards,
therefore this provision could be useful in consolidating reporting and recordkeeping for sources
subject to GGG and MMM. Subpart FFFF (MON) does not contain a similar provision.
3. Compliance with subparts I, GGG, or MMM
Both subparts GGG and MMM (PhRMA and PAI MACTs) allow compliance with
subpart H for equipment leak emission sources. Additionally, subpart FFFF (MON) allows
compliance with either of the programs in subpart GGG or subpart MMM and with subpart H.
Therefore, a facility with equipment subject to these three subparts could comply with one
consolidated program.
4. Compliance with subpart FFFF for affected wastewater
For wastewater streams that have triggered applicability to the control requirements
under subpart GGG or MMM (PhRMA and PAI MACTs), subpart FFFF (MON) provides an
option to comply with the provisions for wastewater in subpart FFFF for all of the wastewater.
G. Summary of the Process Unit Group Option
Both subparts MMM and FFFF (PAI MACT and MON) contain an option called the
Process Unit Group (PUG) that allows the source to designate equipment that is multipurpose
and subject to different MACT requirements over time to be subject only to the MACT standard
36
-------
that applies to the primary product. The PUG approach as described in subpart FFFF allows a
facility to combine all processes that are run in nondedicated equipment, where some of the
equipment overlaps among the processes, into a single entity (i.e., a PUG) for regulatory
purposes. Then, for all of the processes in the PUG, the facility may comply with the rule that
applies to the primary product produced in the PUG. In subpart MMM, the PUG concept is
slightly more restrictive in that it only allows the pieces of equipment that are multipurpose to be
included in the PUG, and not the remaining equipment within the process that contains the
multipurpose equipment. However, the broader, less restrictive language in subpart FFFF
applies to PAI units as well and therefore can effectively supercede subpart MMM requirements.
As an important point of clarification, we note that the PUG concept does not allow
aggregation of process units into a PUG where only control devices, and not processing
equipment, are shared. These circumstances do not reflect operations using multipurpose
equipment processors for which the PUG concept was developed.
Table 8. Summary of Relevant Overlapping Provisions
Provision
40 CFRPart 63 MACT Subparts
GGG
(PhRMA
MACT)
MMM
(PAI MACT)
FFFF
(MON)
Consistency with other MACT standards. After the
compliance dates specified, an affected source subject to the
provisions of this subpart that is also subject to the provisions
of any other subpart of 40 CFR part 63 may elect, to the
extent the subparts are consistent, under which subpart to
maintain records and report to EPA.
63.1250(h)(l)
63.1360(i)(l)
Not
applicable
Compliance with subpart I of this part. After the compliance
dates specified, an affected source with equipment subject to
subpart I of this part may elect to comply with either the
provisions of (insert this subpart) or the provisions of subpart
H of this part for all such equipment.
63.1250(h)(4)
63.1360(i)(4)
Not
applicable
Compliance with subpart I, GGG, or MMM of this part 63.
After the compliance dates specified in §63.2445, if you have
an affected source with equipment subject to subpart I, GGG,
or MMM of this part 63, you may elect to comply with the
provisions of subpart H, GGG, or MMM of this part 63,
respectively, for all such equipment.
Not
applicable
Not applicable
63.2535(d)
Compliance with subpart GGG of this part 63 for
wastewater. After the compliance dates specified in
§63.2445, if you have an affected source subject to this
subpart and you have an affected source that generates
wastewater streams that meet the applicability thresholds
specified in §63.1256, you may elect to comply with the
provisions of this subpart FFFF for all such wastewater
streams.
Not
applicable
Not applicable
63.2535(e)
37
-------
TableS. (continued)
Provision
40 CFRPart 63 MACT Subparts
GGG
(PhRMA
MACT)
MMM
(PAI MACT)
FFFF
(MON)
Compliance with subpart MMM of this part 63 for
wastewater. After the compliance dates specified in
§63.2445, if you have an affected source subject to this
subpart, and you have an affected source that generates
wastewater streams that meet the applicability thresholds
specified in §63.1362(d), you may elect to comply with the
provisions of this subpart FFFF for all such wastewater
streams (except that the 99 percent reduction requirement for
streams subject to §63.1362(d)(10) still applies).
Not
applicable
Not applicable
63.2535 (f)
III. Consolidation Approaches
Two general approaches are available for consolidating requirements when multiple
MACT rules (i.e., subparts GGG, MMM, and/or FFFF) apply to nondedicated equipment. The
approach to use depends on what nondedicated equipment is shared among processes in different
source categories. If processing equipment is shared, then the PUG provisions in subpart MMM
or subpart FFFF can be used to identify a single rule to comply with for all processes that share
the equipment. If the processes share only control devices and/or wastewater management and
treatment systems, then a variety of other provisions that address overlapping provisions must be
used, along with an evaluation of the specific applicable requirements, to determine a control
strategy that will ensure compliance with each rule. Each of the three MACT rules contains
language that address overlapping requirements for storage tanks, wastewater, and equipment
leaks. Thus, the detailed comparison of applicable requirements will generally be limited to the
process vent standards. While the formats and requirements of process vent standards are
generally consistent, there are slight differences which could lead to some confusion regarding
consolidated applicable requirements.
The Appendix presents six case studies that illustrate these concepts for various
scenarios. Three of the case studies use the PUG concept and two of the case studies present
approaches to developing a consolidated set of requirements. Table 9 presents a tabulated list of
the case studies and a summary of what consolidation approach best simplifies compliance
requirements.
Since the compliance date of subpart FFFF (MON) is later than that of subpart GGG
(PhRMA MACT) or subpart MMM (PAI MACT), an owner or operator must comply with
subparts GGG and MMM as written until the compliance date of subpart FFFF. At that time, the
facility could report its intent to consolidate requirements under the notification of compliance
status report and make the necessary permit modifications under title V.
38
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Table 9. Summary of Case Studies
Case
Study
1
2
o
3
4
5
6
Applicable MACT Standards
GGG
(PhRMA
MACT)
MMM
(PAI
MACT)
FFFF
(MON)
Shared Process
Equipment
yes
yes
no
no
yes
no
Shared Control
Devices or WW
Management
Units
yes
yes
no
yes
yes
yes
Consolidation
Techniques
PUG
PUG
None
None
PUGa
See summary of
consolidated
requirements
' The case study also describes consolidation requirements in the event that the PUG option is not selected.
39
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40
-------
Appendix A
Six Case Studies
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A-2
-------
Appendix A
Six Case Studies
The case studies are based on information from two facilities that meet the major source
threshold for HAPs and use nondedicated processing equipment. None of the case studies
precisely represent any specific process(es). Assumptions were made to fill in data gaps and to
allow the case studies to illustrate different scenarios. Changes also were made to simplify the
illustrations and to remove confidential information.
Case Study 1Area 1
Overview
Area 1 contains nondedicated processing equipment that is used to make two end
products and two intermediates for one of the end products. Product P is produced in a PAI
process unit that is subject to 40 CFR part 63, subpart MMM, because this product is a PAI as
defined in subpart MMM and the process uses HAP. The production of the other end product is
conducted in a miscellaneous organic chemical manufacturing process unit (MCPU) that is
subject to 40 CFR part 63, subpart FFFF, because the product (Product Ml) is an organic
chemical in SIC 2879, the process uses HAP, and the process unit is not subject to any other
MACT rule. The intermediates for this end product are isolated intermediates (Products M2 and
M3) as specified in subpart FFFF because they are stored (in drums) before being used as raw
materials in the process to produce the end product. The process units for the intermediates also
are MCPUs under subpart FFFF because the intermediates are in SIC 2869, the processes use
HAP, and the process units are not subject to any other MACT rule. Products Ml and M2 can
be produced simultaneously; other products must be produced one at a time.
General Discussion of MACT Requirements
Table A-l summarizes the emission standards that apply to each of the four process units
making products P, Ml, M2, and M3. Emission limits for transfer operations are not shown in
the table because they do not apply to any of the process units (subpart MMM does not have
standards for transfer operations, and Products Ml, M2, and M3 are not loaded into tank trucks
or rail cars).
The only HAP involved in the production of Product Ml is toluene as a solvent, which is
supplied from drums. Wastewater that contains toluene is generated from the discarded water
layer after reaction, from discarded water-based solutions used to wash the organic filtrate, and
from water used to clean the process vessels. The spent toluene from process operations and
cleaning is also considered wastewater. Except for the wastewater generated from washing the
product, all of the toluene-containing wastewater is also hazardous waste. The hazardous waste
is incinerated in an onsite hazardous waste incinerator. Hazardous waste tanks are not storage
tanks because they are exempted in the definition of "storage tank" in subpart FFFF; however,
they are subject to 40 CFR part 264/265, subpart CC. Figure A-l is a process flow diagram for
this process.
A-3
-------
Table A-l. Applicable Standards for Case Study 1
Process
Product P
Product Ml
Applicable
rule
MMM
FFFF
Do the standards apply to the process?
Process vent
Yes. Because
uncontrolled
organic HAP
(toluene) emitted
from batch
process vents is
>3301b/yr. No
control required
forHCl/Cl2
because HC1/C12
emissions are
<6.8 Mg/yr.
No. All vents
are batch process
vents, the
collective
organic HAP
emissions are
<10,000 Ib/yr,
and there are no
HC1/C12
emissions.
Storage tank
No. The only
storage tank is for
HC1 solution, but
it is <20,000 gal.
Other reactants
and solvents are
supplied from a
gas cylinder,
drum, or tank
truck.
No. There are no
storage tanks
associated with
the process. Raw
materials are
supplied from
drums or bags,
and product is
drummed out.
Equipment leak
Yes. At least some
equipment
components are in
organic HAP
service for more
than 300 hr/yr.
Yes. At least some
of them are in
organic HAP
service for more
than 300 hr/yr when
all processes are
considered.
Wastewater
Yes, for the
organic waste and
rag layer.
Wastewater from
washing the filter
cake, distillation,
and cleaning
vessels contains
toluene at less
than 1,000 ppmw
and, thus, is not
subject to control.
Yes. The spent
toluene from
process operations
and cleaning
would be Group 1
wastewater.
Wastewater from
the decanter,
filtrate washing,
and water-based
process vessel
cleaning are
Group 2 because
they are one-
phase streams
with
-------
Table A-l. Applicable Standards for Case Study 1 (continued)
Process
Product M2
Product M3
Applicable
rule
FFFF
FFFF
Do the standards apply to the process?
Process vent
Yes.
Uncontrolled
organic HAP
emissions from
batch process
vents exceeds
10,000 Ib/yr.
Yes.
Uncontrolled
organic HAP
emissions from
batch process
vents exceeds
10,000 Ib/yr.
Storage tank
No. All reactants
and solvents are
supplied in
drums, and the
product is
drummed out.
No. All reactants
are supplied from
drums, as a solid,
or from gas
cylinders. The
product is
drummed out.
Equipment leak
Yes. Same
rationale as for
Product Ml.
Yes. Same
rationale as for
Product Ml.
Wastewater
Yes. Three
wastewater
streams exceed
the Group 1
thresholds: the
spent methanol
cleaning solvent
contains >30,000
ppmw methanol,
the water layer
from the toluene
extraction
contains >30,000
ppmw methanol,
and the rag layer
from the
extraction
contains more
than 1,000 ppmw
toluene.
Wastewater from
water-based
cleaning is Group
2 because it has
< 1,000 ppmw
HAP.
Yes. The rag
layers and
primarily organic
waste streams
would be Group 1
for toluene and/or
chlorobenzene.
Wastewater from
the distillation
operations and
vessel cleaning
are Group 2
because they are
single-phase
streams that
contain < 1,000
ppmw of toluene
and/or
chlorobenzene.
A-5
-------
solid reactants from bags
makeup raw materials
makeup raw materials^
toluene rinse before campaig
water
Toluene (from drums) and other solvents
' to flare
lign f
~^k_ij'v *' !
Product M3 from drums
R-410
Reactor
all aqueous cleanout from process;
toluene from drums
makeup from drums
non-HAP
organic
solvent
dump tank
recovered toluene mix solvent
makeup from drums
ation bottoms
R-120
Non-HAP
solvent for
emergency
quench
_
T-2400
tank
Product M2 from drums
solid neutralizing raw materia
_*JI«L^
i.
' 1
' 1
vacuum pump to flare
.............
spent toluene rinse from start
of campaign to waste drums
Figure A-l. Process flow diagram for production of Product Ml.
-------
The HAP involved in the production of Product M2 include vinyl acetate and ethylene
glycol as reactants, methanol as a reactant and solvent, and toluene as an extraction solvent. All
of these HAP materials are supplied from drums, and the product is drummed out. Wastewater is
generated from extraction, water-based cleaning of process vessels, methanol cleaning of process
vessels, the light ends from distillation, and the distillation residue. All of these wastewater
streams, except the water used to clean the process vessels, are also hazardous waste. The
hazardous waste is hard-piped to tanks or drums, but these vessels are not considered storage
tanks under subpart FFFF. The resulting hazardous waste is incinerated in an onsite hazardous
waste incinerator. Figure A-2 is a process flow diagram for this process.
The HAP involved in the production of Product M3 include chlorobenzene as a reactant,
toluene as an extraction solvent, and hydrogen chloride (HC1) as a reaction byproduct. The
chlorobenzene and toluene are both supplied from drums, not storage tanks. Wastewater is
generated from washing the organic layer to remove impurities, from both distillation units, and
from cleaning the process vessels. The discarded rag layers and the primarily organic waste
streams are also considered wastewater and hazardous waste. Hazardous waste is incinerated in
an onsite hazardous waste incinerator, and the vessels used to store hazardous waste are not
storage tanks under subpart FFFF. Figure A-3 is a process flow diagram for this process.
The HAP involved in the production of Product P include chlorine as a reactant; HC1 as a
reactant, extraction solvent, and pH adjuster; and toluene as an extraction solvent. The HC1 is
supplied from a storage tank, the chlorine from gas cylinders, and the toluene from a tank truck.
Wastewater is generated from cleaning process vessels with water, the water layer in the
distillation receiver, filtering the product slurry, and washing the filter cake. The organic waste
and rag layer from the extraction step would also be considered wastewater. Figure A-4 is a
process flow diagram for this process.
A-7
-------
to flare
toluene from drums
>
oo
T-500
from drums ^ vinyl acetate
drop tank
neutralizing solution
Gaseous reactant from gas cylinder
1 <"
>
V
R-250
Toluene emergency
quench vessel
ethylene glycol and organic
catalyst from drums
to condenser and scrubber
k/^T)f vacuum pump to flare
metnanoi tiusn (inc. in batcn) XrJ \ V
v ir " !
methanol from drums f R-390 1 R-160 R-1 ]* » R "0
fc r°ar*"r 1- - u»u:_« . i. t. riistillatmn 1 receiver
Additionally:
Water used to clean equipment
between batches drained to sumps
as wastewater.
Spent solvent from cleaning with
methanol at start of campaign
discharged to T-5020 HW tank.
|-, ,. y ^ |
1 k
Organic layer Various cuts: "~
light ends to HW tank 1-5020,
recovered EG to drums for recycle
toluene from drums (or to HW tank if spent),
for first batch Product M2 to drums
tn flam
J. ^ ^.
Aqucou~ and v ! ' riistillatinn rasiriiifi
"raqiaTers" R'280 R'290 to waste drums
vessel water layer and toluene extract
Caustic solution
*
T-5010
water layer (wastewater) ^ "qucou- HW
to flare St°rage
1
1
mostly T 130o
organic layer ^ ,,, tanlr , water and rag layers
toluene/product mix
organic layer (to distill in R-150)
Figure A-2. Process flow diagram for production of Product M2.
-------
Clorobenzene
from drums or
T-600
To scrubber
To flare
Solid raw material that
contains chlorine
Gaseous raw material
R-120
Reactor
toluene from drums and water
to clean at start of campaign
Water
R-270
Hydrolysis
reactor
>
rag layer to waste drum
Separator
rag layer to waste drum
Additionally:
Empty pails that contained the
chlorinated raw material are
washed in a small enclosure. An
elephant trunk is place over the
enclosure vent to draw off HCI
vapors.
T-700
Waste holding tank
Chlorobenzene
from T-600 or
T-4070
Aqueous
layer
Toluene from drums
To scrubber
Atmospheric
vent to scrubber,
or vacuum vent
though knock
out pot to flare
To scrubber
Water wash
V
R-390 organ
^ extraction laVer
0 T-2300
L
S
1
R-400
still
Wastewater at end of campaign k
To scrubber^
2400 ^| Organic laye
r
&*
Bottoms to be mixed
with chlorobenzene,
neutralized, and
incinerated
1^. T-600
receiver
Various cuts
including recovere
chlorobenzene (to
-, T Amr\ r,r T ORm
product M3 (to
drums), and
waste water.
To scrubber
i
spent chlorobenzene
waste ^
Wastewater
rag layer and spent toluene
Figure A-3. Process flow diagram for production of Product M3.
-------
from tank truck
to flare
Raw materials
to scrubber
R-160
chlorinator
to scrubber
HCI from T-2600
51003-D
Holding vessel/
extraction
organic waste A
(possible recovery) J
-+^_ ^^
Cl2
from drums
to scrubber w
i
i
^ rr-4070^1
l_l/^l 1
ns I HUI J
T
r 1
water phase
r
caustic from truck
rR-390
neutralizer
>p-330J
Additionally:
All wastewater from cleaning
before campaign and at end
of campaign is drained to
sump.
organic raw material makeup
HCI from drums
Wet product drummed
and sent to dryer
(uncontrolled)
wastewater
to sump or
recycle
Figure A-4. Process flow diagram production of Product P.
-------
Overlapping Situations and Strategies for Minimizing Overlap
Numerous process vessels are used in the production of both Product P and one or more
of the other products. For example, vessel R-390 is used in the production of products P, M2,
and M3; vessel R-420 and the filter are used in the production of products P and Ml; and vessel
T-4070 is used in production of products P, Ml, and M3. Therefore, the process vent standards
in both subpart MMM and subpart FFFF apply to these vessels (and others) at different times,
and the monitoring requirements in both rules apply to the control devices used for the emission
streams. Similarly, various equipment components are subject to the LDAR requirements in
both rules. Finally, the wastewater management and treatment requirements in both rules and
the Resource Conservation and Recovery Act (RCRA) apply to the piping, tanks, and incinerator
used by all of the processes. The rules include options, however, for dealing with each of these
overlapping situations.
Since processing equipment used for Product P is shared with each of the other three
processes, a PUG may be developed that encompasses all four process units. In this example,
the primary product is material subject to subpart FFFF (i.e., the sum of the operating time for
products Ml, M2, and M3 is greater than the operating time for Product P over the 5-year
period), so the facility could elect to comply with subpart FFFF for all four process units.
(Alternatively, if Product P were the primary product for the PUG, then the owner or operator
could elect to comply with subpart MMM for all four process units.) The hazardous waste
incinerator is not subject to any provisions in subparts MMM and FFFF because both subparts
exempt RCRA hazardous waste incinerators from initial and ongoing compliance requirements
as well as recordkeeping and reporting requirements. Subparts MMM and FFFF also state that
an owner or operator may determine which rule (RCRA or the MACT) contains the more
stringent control requirements (e.g., management requirements for wastewater tanks) and comply
only with that rule. That determination is beyond the scope of this study.
If the owner or operator elects not to develop a PUG, then the process vent requirements
in both rules would apply, including initial compliance, monitoring, recordkeeping, and
reporting. Subpart FFFF specifies that an owner or operator with affected sources under
subparts FFFF and MMM may elect to comply with the equipment leak provisions in either rule
for all equipment components. Similarly, for affected sources under both subparts, an owner or
operator may elect to comply with the wastewater provisions in subpart FFFF for all wastewater
streams (although the HAP concentration and wastewater flow thresholds for control in subpart
MMM still apply for Product P).
Effect of Other Operating Conditions on Overlap
1. What if Product Ml is a PAI? The two intermediates (M2 and M3) would not be integral
intermediates under subpart MMM because they are stored. Thus, the intermediates would be
subject to subpart FFFF, not subpart MMM. However, subpart MMM allows you to designate
any intermediates for PAI process units to be PAI process units themselves, even if they are not
integral intermediates. Thus, you could comply with subpart MMM for all four process units.
Alternatively, you could try to develop a process unit group that would allow compliance with
A-ll
-------
subpart FFFF; if the production of the two intermediates exceeds the production of the two end
products, then the primary product for the PUG would be material subject to subpart FFFF, and
you could comply with subpart FFFF for all four process units.
2. What if toluene were supplied from a 10.000 gal storage tank? Storage tanks must be
assigned to the process with the predominant use for the tank. If the predominant use is for
Product P (or a process unit group with PAI products as the primary product), then there would
be no requirements because existing source storage tank standards in subpart MMM apply only
to tanks with capacities of at least 20,000 gal. There also would be no requirements if the
predominant use is for Product Ml, M2, or M3 (or a PUG with material subject to subpart FFFF
as the primary product) because subpart FFFF does not require control of storage tanks storing
material with a maximum true vapor pressure (MTVP) of HAP less than 1 psia (toluene is about
0.5 psia).
3. What if Product P is an intermediate for a PAI process in a separate area of the plant?
Assuming Product Pisa liquid that is discharged to a storage vessel, Product P would not meet
the definition of an integral intermediate because it is stored, and the production of Product P
and the final PAI occur in separate processing areas. Thus, all four processes would be subject
to subpart FFFF.
A-12
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Case Study 2Area 2
Overview
General Description
Area 2 houses the equipment used to manufacture a variety of products and is known as a
multipurpose production facility. The permit application for the facility lists 15 products that the
facility could make, including UV stabilizers for paints, an oil additive, a circuit board
developer, a corrosion inhibitor, and several other pesticide intermediates and PAIs.
Additionally, the application indicates that Area 2 is used in formulation and packaging of
various herbicides (i.e., PAIs) and specialty chemicals. This case study is based on the
production of three end products manufactured in the area: Products A, B, and C. The
manufacturing processes for all three products are subject to 40 CFR part 63, subpart MMM (the
PAIMACT) because the products are PAIs as defined in subpart MMM, and the processes use
and emit HAP. Product C is actually manufactured at another site, sent to Area 2 for
purification, and sent back to the originating facility. This purification step is subject to the PAI
MACT because the definition of the term "process" in subpart MMM includes purification unit
operations. For the purpose of this illustration, we assumed that the intermediate production
steps associated with the manufacture of Product B are subject to subpart FFFF because they do
not qualify as integral intermediates, as defined in subpart MMM, and they emit HAP.
Therefore, equipment in this facility has the potential to be subject to both subpart MMM and
subpart FFFF of 40 CFR part 63. Each of the three processes reviewed is discussed in greater
detail below.
Product A is produced by several reactions involving HAP and non-HAP raw materials.
HAP compounds associated with the process include HC1, hydrogen fluoride (HF), and trace
levels of xylene associated with solvent. Vents from the process prior to the introduction of
solvent into Reactor D-3208 are composed primarily of HC1, HF, and sulfur dioxide (SO2) and
are routed to the Area 2 caustic scrubber. Once the organic solvent is introduced, vents from
remaining process vessels are directed to the facility's vent gas combustor. A simplified process
flow diagram is presented as Figure A-5.
A-13
-------
To Vent Gas
Combustor
Condensate to 3230-F
> Final Product
3201-1
Strippi
-D'3210-D L Organ
Tippers 1^
to 3233-F for Incineration
Stripped Water to Sump or Incinerator
Figure A-5. Process flow diagram for production of Product A.
-------
The production of Product B involves a three step reaction process that begins with the
formation of an intermediate from raw materials. The HAP associated with the first product step
include HC1, which is a reactant, and toluene, which is used as a solvent for the intermediate.
The second processing step involves the hydrogenation of the intermediate to form a second
intermediate. HAP associated with this step are the toluene solvent and methanol, which is used
to wash the catalyst. Finally, the third step of the process involves the reaction of the second
intermediate to form the PAI product. The HAP associated with the third step of this process is
toluene. A simplified process flow diagram is presented in Figure A-6. Note that the facility's
permit application indicates that intermediate products from Step 1 and Step 2 are "stored" prior
to further processing. This storage step has implications for the applicability of the PAI MACT,
as the intermediates produced in Steps 1 and 2 may not be considered integral intermediates and
therefore not trigger applicability to the PAI MACT. However, as noted above, these steps
would be covered by the MON if they do not qualify as integral intermediates. Product C is a
purification process that uses the HAP acetonitrile. A simplified flow diagram is presented in
Figure A-7. Processes A, B, and C cannot be operated at the same time, as the use of some of
processing equipment is shared.
HAP Emissions Information
The facility's title V permit application provides uncontrolled emission rates of HC1 into
the scrubber of 94 Ib/hr and provides a scrubber efficiency of 99.99 percent. Emissions of HF
have not been quantified but are reported as trace. Although some organics are reported from
the scrubber, none are HAP. HAP emissions reported from the facility's vent gas combustor
include toluene, methanol, HC1, and HF. Destruction efficiency of organics in the vent gas
combustor is reported to be 99.99 percent. During the hydrogenation step associated with
Product B, emissions of toluene are vented through a condenser system and then directly to the
atmosphere. Some equipment in Area 2 also has the capability of venting to the atmosphere
from the facility vent system. HAP emissions of HC1 and HF are reported from this system.
Finally, there are several storage tanks containing toluene and methanol at the facility which
appear to be capable of venting directly to the atmosphere via the facility's vent system, or to the
vent gas combustor (the title V permit provides either scenario as an option). There are also
several sources of wastewater.
General Discussion of MACT Requirements
Table A-2 presents a general description of requirements for the three products. Subpart
MMM requires 90 percent control of all process vents within a PAI process unit if uncontrolled
emissions exceed 330 Ib/yr. Based on the emission rates described above, Processes A, B, and C
will trigger applicability to process vent control requirements. Likewise, during the production
of intermediates in Steps 1 and 2 in Process B, process vent control requirements in subpart
FFFF also will be triggered. All three processes will trigger control requirements for equipment
components, storage tanks, and wastewater.
A-15
-------
Final Product to
Blend
Figure A-6. Process flow diagram for production of Product B.
A-16
-------
From Trailers
Raw material in
220 Ib drums
ACETONITRILE
STORAGE
To Vent Gas
Combustor
3207-D
+
M
^
J>
3208-D
-*
Filtration
and
activated
carbon
\
,_ \
Purified
Product
Aqueous Waste
to Incineration
Vent to scrubber
through hose
Figure A-7. Process flow diagram for production of Product C.
A-17
-------
Table A-2. General MACT Requirements for Case Study 2
Product
Process
A
B (step 3)
C
B (steps 1
and 2)
Rule
PAI
MON
Process
vents
Yes. Sum of
process vent
HAP
emissions
exceeds
330 Ib/yr.
Yes. Sum of
process vent
HAP
emissions
may exceed
10,000 Ib/yr.
Storage
tanks
No,
although
MTVPof
toluene and
methanol
tanks
exceed
threshold,
tanks are
below
20,000
gallons.
Yes.
Toluene
and
methanol
tanks are
above
10,000 gal.
Equipment
leaks
Yes. Some
equipment
components
will be in
HAP service
>300 hr/yr.
Wastewater
No points of
determination
(PODs)
Yes. PODs with
methanol
identified.
No PODs
No PODs
Transfer
operations
Not
applicable
No. Loading
thresholds
will not be
exceeded.
Overlapping Situations and Strategies for Minimizing Overlap
Because the manufacture of Products A, B, and C share processing equipment, there will
be an overlap in applicability between subparts MMM and FFFF, particularly for process vents
and equipment leaks. The owner or operator could consolidate compliance with both rules using
the PUG concept that is provided in subpart FFFF. The PUG approach is available for
equipment that is used to manufacture more than one product, and termed "nondedicated."
Using the PUG approach, the owner or operator would identify equipment that are part of a
nondedicated MCPU. In Area 2, these equipment would be those reactors and processing
equipment that could be used to make either PAI or MON products. The PUG would then
include each processing unit that contains equipment that overlaps with any other processing
equipment. After establishing the PUG, the owner or operator would then identify the primary
product of the PUG and comply with the rule that applies to the primary product for all such
equipment in the PUG. This approach would serve to consolidate MACT requirements and
eliminate duplicative recordkeeping provisions.
A-18
-------
Case Study 3Area 3
Overview
General Description
Area 3 is primarily known as a formulations plant. The unit contains equipment used to
manufacture three end products and to formulate these end products via blending with water,
solvents, or surfactants and other products. The manufacturing process for one end product is
subject to 40 CFR part 63, subpart MMM, because the product is a PAI as defined in subpart
MMM, and the process uses HAP. The building houses one prereactor and four finishing
reactors; a batch still; and numerous raw material, blend, and product storage tanks. Only one
end product can be produced at a given time. A simplified diagram is presented as Figure A-8.
From the flow diagram, the prereactors and the finishing reactors are each equipped with
their own condensers. There are no other devices that are used to control emissions for
equipment in Area 3.
HAP Emissions Information
The only HAP emitted from Area 3 is 2-butoxyethanol, a glycol ether. Further, the
Area 3 permit application lists emissions after control of 2-butoxyethanol of 396 Ib/yr, with
362.3 Ib/yr estimated from the vent header and the remaining 33.9 Ib/yr from a raw material
tank. No HAP are emitted from the formulation operations.
Identification of Process Units
The boundaries of the PAI process unit are shown on the process flow diagram as
Product A. Note that per the definition of "PAI process unit" in subpart MMM, the formulation
operations in Area 3 are not considered part of the PAI process unit.
General Discussion of MACT Requirements
Table A-3 presents a general description of requirements for the PAI process unit.
Subpart MMM requires 90 percent control of all process vents within a PAI process unit if
uncontrolled emissions exceed 330 Ib/yr. Based on the reported emission rate from the vent
header, Process A will meet this trigger for process vent control. Additionally, the components
in 2-butoxyethanol service to be subject to the LDAR requirements. The MTVP (vapor pressure
at maximum bulk storage temperature) of 2-butoxyethanol is below the applicability cutoff for
control of storage tanks of 3.45 kPa (0.5 psi).
A-19
-------
to
o
Product A - PAI
Process Unit
Nondedicated
Formulation
MCPU
Figure A-8. Process flow diagram for production in Area 3.
-------
Table A-3. General MACT Requirements for Case Study 3
Process
A
Applicable rule
PAI MACT
Process vents
Yes. Sum of
process vents
exceeds
330 Ib/yr
uncontrolled
emissions.
Storage tanks
No. MTVP of
HAP is below
3.45kPa.
Equipment leaks
Yes. Some
equipment
components will
be in HAP
service for
>300 hr/yr.
Wastewater
No. There are
no process
wastewater
streams from
this unit.
Overlapping Situations and Strategies for Minimizing Overlap
As currently configured, sources in Area 3 are not subject to more than one MACT
because there are no instances of shared processing or control equipment.
Effect of Other Operating Conditions on Overlap
1. What if formulation products use HAP?
Subpart MMM specifically exempts formulation of pesticide end product. However,
subpart FFFF covers the production of organic chemicals that use, produce, or process HAP that
are not covered by other MACT standards. If HAP are used in formulation, subpart FFFF would
apply to the formulation operations identified in Figure A-8 and these equipment would
constitute an MCPU during the production of MON products. The processing equipment and
control devices used in the PAI process unit and the MCPU would not overlap, unless the same
HAP (2-butoxyethanol) was used in both process units. In this case, it is possible that the HAP
storage tank and equipment components in supply lines such as pumps, valves, and connectors
from the HAP storage tank to the process units would potentially be subject to two standards.
Both subpart MMM and subpart FFFF require the owner or operator to assign storage tanks to a
process unit based on throughput to each process unit. Therefore, there is essentially no
potential for overlap from the storage tank. For LDAR, the MON specifically allows compliance
with other programs, such as the program required by subpart MMM. Therefore, the facility
could apply one consolidated LDAR program to components in Area 3.
A-21
-------
Case Study 4Area 4
Overview
General Description
Area 4 contains the equipment used to manufacture several different products, including
an antimicrobial agent, a chemical intermediate, a biocide, a heat transfer fluid, and two pesticide
active ingredients (Products A and B). No HAP are used, produced, or processed in the
manufacturing processes for the antimicrobial agent, the chemical intermediate, the biocide, or
the heat transfer fluid. However, HAP are used in the production of both PAIs. In the
manufacture of Product A, 2-butoxy ethanol is used as a raw material. Triethylamine is used as a
raw material in the manufacture of Product B. Processes A and B share the same equipment, so
only one product can be produced at any given time. Because Products A and B are registered
PAIs, both manufacturing processes would be covered by subpart MMM. The formulation of a
pesticide end product using product A, however, would be covered by subpart FFFF since
subpart MMM specifies that formulation is not covered, and the formulation process uses HAP
(xylene is a component of the formulation solvent). We identified this formulated product as
Product C.
A simplified process flow diagram for the manufacture of Products A , B, and C is
provided in Figure A-9. From the process flow diagram, process vents from the reactor that is
used to manufacture the PAI products, as well as the blend tank where Product A is formulated,
are controlled by a water scrubber. Raw material storage vents for aromatic-200 (the solvent that
contains xylene), triethylamine, and 2-butoxyethanol are uncontrolled.
HAP Emissions Information
Yearly HAP emissions composed of 2-butoxyethanol, triethylamine, and xylene from
process vents and storage for both processes, after control, are reported to be approximately
1,000 Ib/yr in the permit application.
Identification of Process Units
The boundaries of the PAI process units (Products A and B) and the MCPU (Product C)
are identified in Figure A-9.
A-22
-------
PAI
Process
Units -
Products
A and B
HAP Raw Materials (RM) for
Product A:
2-Butoxy Ethanol
For Product B:
Triethylamine
Aromatic-200 contains
HAP and is used for
formulation of Product
A
Figure A-9. Process flow diagram for production in Area 4.
A-23
-------
General Discussion of MACT Requirements
Table A-4 presents a general description of requirements for the PAI process units and
the MCPU. Emissions data indicate that HAP emissions from process vents associated with
Processes A and B would trigger control requirements for subpart MMM. However, because
xylene process vent emissions, after control, are reported to be fairly low (49 Ib/yr), and
considering the fact that the water scrubber would not be effective for the control of xylene, the
process vent emissions from the formulation process (Process C) would not trigger process vent
control requirements for subpart FFFF. Storage of xylene-based aromatic solvent also would not
trigger storage tank requirements under subpart FFFF because the MTVP of the xylene in the
Aromatic-200 does not exceed depending on the actual composition of the solvent and the tank
capacity. Some equipment components in all three processes are in organic HAP service; thus
triggering the LDAR requirements under both subparts MMM and FFFF.
Table A-4. General MACT Requirements for Case Study 4
Process
A
B
C
Rule
PAI
MACT
PAI
MACT
MON
Process vents
Yes. Sum of
process vents
exceed 330 Ib/yr
uncontrolled
emissions.
No. Sum of
process vents do
not exceed
10,000 Ib/yr
uncontrolled
emissions.
Storage tanks
No. MTVP of HAP is
below 3.45 kPa.
Yes. MTVP of HAP is
>3.45 kPa and capacity
is >20,000 gal
No. The MTVP of
HAP does not exceed
6.9 kPa.
Equipment
leaks
Yes. Some
equipment
components
are in
organic HAP
service for
>300 hr/yr.
Wastewater
No. PODs
contain
<1,000 ppmw
Table 9 HAP.
No. POD will
likely not
exceed cutoffs.
Transfer
operations
No. PAI
MACT does
not cover
these
operations
No.
Loading
thresholds
are below
cutoffs.
Overlapping Situations and Strategies for Minimizing Overlap
As currently configured, sources in Area 4 are not subject to more than one MACT
because there are no instances of shared processing or control equipment.
Effect of Other Operating Conditions on Overlap
1. What if HAP emissions from Process C exceed 10.000 Ib/yr?
If HAP emissions of xylene from the formulation operations (Process C) were to exceed
10,000 Ib/yr on an uncontrolled basis, the facility would have to install a control device that
would be effective in controlling xylene emissions. However, there would still be no overlap in
processing equipment, and since the existing scrubber system could still be used to control HAP
from Processes A and B, there also would be no overlap in control equipment.
A-24
-------
Case Study 5Area 5
Overview
General Description
Area 5 contains the equipment necessary to manufacture a number of ion exchange
resins. Most of the resins are MON products (subject to subpart FFFF); two are pharmaceutical
products (subject to subpart GGG). Figure A-10 contains a simplified flow diagram describing
the relevant equipment and processes in Building 3. From the figure, the initial starting point for
the manufacture of all ion exchange resins is the manufacture of an intermediate ether
compound, which we have named Product A. This is accomplished in reactor 1 using methanol,
HC1, a non-HAP reactant, and recycled organics from the later stages of the resin manufacturing
processes. The HAP emissions from reactor 1 are routed through a condenser system, and
remaining gases are routed in series through two scrubbers and the "afterburner," or thermal
oxidizer system, which is reported to achieve a control efficiency of 99.9 percent. The methanol
storage tank is uncontrolled. Product A may be subsequently stored prior to further processing
as a raw material for manufacturing the ion exchange resins. This means Product A is an
isolated intermediate under both subpart GGG and subpart FFFF. Thus, the manufacture of
Product A is conducted in a dedicated MCPU that is distinct from process units for the
downstream resin process trains.
The production of ion exchange resins occurs simultaneously in three identical trains that
follow the Product A production process (for simplicity, Figure A-10 shows only one of these
trains). The process trains are operated in essentially the same manner, where the Product A is
reacted with copolymer to make an intermediate resin that is heated, then cooled and washed
with an organic liquid. The process trains are used to produce some resins that are MON
products and other resins that are pharmaceutical products. In Figure A-10, the MON resins are
identified as "Products B," and the pharmaceutical resins are identified as "Products C." The
reactors in the process trains are vented through a condenser that is followed by a refrigerated
absorber system and a scrubber. Organic compounds are recovered using several distillation
systems. Noncondensables from the distillation system are routed to scrubber 1. A second
reaction with amines is conducted to make final product anion resins. Vent gases from this
reactor are sent to scrubber 3. Finally, the anion resin is transferred to a final reactor where it is
washed with water. Vent gases from the final reactor are sent to scrubber 4.
The building also houses a group of smaller reactors that are used to make a certain class
of specialty resins. All of these resins are MON products. In Figure A-10, these resins are
identified as "Products D." Several of these resin products require ethylene dichloride (EDC), a
HAP, as a raw material. Vents from the distillation operation are vented to the afterburner
system without first passing through scrubbers. Once the EDC and other organic compounds
have been removed from the resin in the distillation operation, vents from the second wash stage
of this process are routed to scrubber 4.
A-25
-------
to
MCPU - Products B
PMPU-Products C
Scrubber
6
1
r
Wash
fis~|
^
i r
Distill
1
k.
^
Reactor 4
h,
w
Wash
Notes:
Wastewater PODs not shown
*IS = intermediate storage
Figure A-10. Process flow diagram for production in Area 5.
-------
HAP Emissions Information
Based on the permit application, numerous HAP are used, processed, and ultimately
emitted from the equipment used for manufacturing Product A and ion exchange resins. Table
A-5 presents the actual HAP emissions from process vents and storage (from the permit
application).
Table A-5. Summary of Emissions Information for Case Study 5
HAP compound
Methyl chloride
Dimethyl ether
Formaldehyde
Methanol
Ethylene dichloride
Hydrogen chloride
Chlorine
Annual emissions, Ib/yr
Afterburner
1,119
97
2
49
1,122
19,100
8,385
Scrubber 4
323
2
19
Methanol
storage
1,004
In addition, six wastewater streams are discharged from the resin production processes,
including the afterburner scrubber effluent. Five of the wastewater streams are Group 1 (and
thus subject to control). The scrubber effluent, however, is Group 2 (and not subject to control)
because the HAP concentration is less than 1,000 ppmw.
Identification of Process Units
The boundaries of the dedicated MCPU process unit and the remaining nondedicated
units are presented in Figure A-10.
General Discussion of MACT Requirements
Table A-6 contains a general description of applicable requirements for sources in
Area 5. Individual processes manufacturing MON products, such as Products A, B, and D
(which include various ion exchange resins) would trigger MON MACT process vent
requirements to control 98 percent of HAP emissions from each MCPU with greater than
10,000 Ib/yr of uncontrolled HAP. Production of the pharmaceutical products would also trigger
process vent control requirements of 93 percent. Other emission sources would also be subject
to applicable requirements, including the methanol storage tank, wastewater management and
treatment systems, and LDAR components.
A-27
-------
Table A-6. General MACT Requirements for Case Study 5
Process
A
B,D
C
Applicable
rule
MON
MON
PhRMA
Process vents
Yes. Sum of
process vents
exceeds
10,000 Ib/yr
uncontrolled
emissions.
Yes. Process
vents must meet
2,000 Ib/yr post
control or 93%.
Storage tanks
Yes. Methanol
storage tank has
capacity
> 10,000 gal.
No. Methanol
storage tank
will be assigned
to MCPU based
on predominant
use.
Equipment
leaks
Yes.
Components
will be in
HAP service
>300 hrs/yr.
Wastewater
Yes. POD
exceeds
applicable
limits.
Transfer
operations
No. Loading
thresholds
are below
cutoffs.
Not
applicable
Overlapping Situations and Strategies for Minimizing Overlap
Because the pharmaceutical products (identified as Products C in Figure A-10) and the
MON products (Identified as Products B in Figure A-10) can potentially be made at the same
time, the control devices, equipment components, and wastewater management and treatment
systems could be subject to both the MON and the PhRMA MACT at the same time. Further,
because the PhRMA products (Products C) and MON products (Products B) can be made in
different process trains (e.g., using nondedicated equipment), the same processing equipment
could be part of an MCPU some of the time and a pharmaceutical manufacturing process unit
(PMPU) at other times. Area 5, therefore, provides an example of overlap stemming from shared
equipment, shared control devices, and shared wastewater conveyance and treatment systems.
Because the processing equipment is shared, our first approach would be to use the PUG
concept, which would not require a case-by-case consolidation approach; however, as an
example, we have developed a consolidation approach that could also be used to illustrate how to
consolidate requirements for shared control devices or waste management units. Both
approaches are described below.
PUG Approach
The most straightforward approach available for this case study is to ensure compliance
with both rules using the PUG concept that is provided in subpart FFFF. The PUG approach is
available for equipment that is used to manufacture more than one product, and termed
"nondedicated." Since the pharmaceutical products can be made in the same equipment as the
other MON products, the owner or operator would have the option to comply using the PUG
concept. Using the PUG approach, the owner or operator would identify equipment that are part
of a nondedicated MCPU. In Area 5, these equipment would be those reactors and processing
equipment that could be used to make either the pharmaceutical or the MON ion exchange resins
A-28
-------
(Processes B and C). The PUG would then include each processing unit that contains equipment
that overlaps with any other processing equipment. Once the PUG is established, the owner or
operator would make a primary product determination. The primary product of this process unit
group would be the MON product, since the PhRMA products were estimated to make up only
about 10 percent of the production of other ion exchange resins (thus the operating time for
Process C is less than for Process B). Based on the determination that the primary product of the
PUG would be MON materials, the owner or operator could comply with the MON for all
equipment in the PUG. This approach would serve to consolidate MACT requirements and
eliminate duplicative recordkeeping provisions. In the case of wastewater, using the PUG
concept might also serve to eliminate conveyance and treatment requirements for methanol-
containing wastewaters if the methanol concentration of wastewater generated by the PMPU
were less than 30,000 ppmw applicability trigger for Group 1 streams provided in subpart FFFF.
Consolidation Approach
Table A-7 shows several possible strategies for consolidating requirements and
minimizing the effect of these overlapping requirements. These strategies include using specific
provisions in the subparts that address overlap. For example, after the compliance dates of
subpart FFFF, if a facility has equipment subject to LDAR requirements in subpart FFFF and the
facility also has equipment that is subject to the LDAR requirements in subpart I, GGG, or
MMM, then subpart FFFF allows compliance with the LDAR provisions of any of the applicable
subparts H, GGG, or MMM for all of the subject equipment. Therefore, it should always be
possible to comply with only one LDAR program. Second, when a facility has wastewater
streams subject to subpart FFFF and other streams that are subject to subparts GGG and/or
MMM, subpart FFFF contains consolidation provisions that allow all of the streams to comply
with the requirements of subpart FFFF. Note, however, that the HAP concentration thresholds
for control in each rule still apply. Thus, if the methanol concentration in the wastewater from
the PMPUs is between 5,200 ppmw and 30,000 ppmw, then control is required even if
complying with the management and treatment requirements of subpart FFFF.
Table A-7. Consolidation Approach for Case Study 5
Emission Source
Process Vents
Storage Tanks
Wastewater
Equipment Leaks
Consolidation Strategy
See Table A-8
Assign tank to subpart FFFF
Comply with subpart FFFF for all affected wastewaters;
§63.2535(e)
Comply with subpart GGG; §63.2535(d)
For process vents, our approach requires a review of each applicable requirement. Our
control strategy assumes that the incinerator alone will achieve the required control efficiency
for organic HAP. For process vents that are subject to both subparts GGG and FFFF and
controlled by one centralized combustion device, there are two basic options: (1) conduct an
initial performance test and set appropriate monitoring parameters to demonstrate continuous
A-29
-------
compliance, or (2) equip the scrubber stack with a CEMS to continuously measure total organic
compounds (TOC) and halogens and hydrogen halides (or, for halogens and hydrogen halides,
demonstrate 95 percent removal from the scrubber). The initial compliance test under option 1
must show either (1) 98 percent removal of organic HAP from the combustion device and
99 percent removal of hydrogen halides and halogens from the scrubber following the
combustion device or (2) outlet TOC concentrations less than 20 ppmv and outlet hydrogen
halide and halogen concentrations less than 20 ppmv). To eliminate monitoring requirements
under Option 1 on the scrubbers upstream of the incinerator, the performance demonstration
should be conducted when the scrubbers are not operational.
Since the compliance date of subpart FFFF is later than that of subpart GGG, the owner
or operator must comply with subpart GGG as written until the compliance date of subpart
FFFF, at which time, the facility could report under the subpart FFFF notification of compliance
report its intent and strategy to consolidate requirements, and make necessary permit
modifications under Title V. The provision allowing consolidation is §63.1250(h)(l) in subpart
GGG, which prompts the operator to comply with both regulations by implementing a strategy
that will assure compliance under both regulations. Appropriate consolidated requirements for
each compliance strategy are summarized in Table A-8.
Table A-8. Specific Consolidation Approach for Case Study 5
Requirement
Organic HAP
Control
Requirement
Halogenated
Stream Control
Requirement
Initial
Compliance
Demonstration
Monitoring
MACT subparts
GGG
(PhRMA)
FFFF
(MON)
/
/
/
/
Option 1
98% or to < 20 ppmv
[Table 2 to subpart FFFF]
99% control of hydrogen halides
and halogens or to <20 ppmv
[Tables 1 and 2 to subpart FFFF]
Initial performance test to
demonstrate 98% or 20 ppmv, 99%
or 20 ppmv based on worst case
Continuous monitoring of
scrubber liquid flow
pH or caustic strength
inlet gas flow rate
gas temperature exiting
combustion temperature
Option 2
Alternative Standard: concentration
standard of 20 ppmv HAP and
20 ppmv hydrogen halides and
halogens [§63.2505]
95% reduction for scrubber control
of hydrogen halides and halogens
[§63.2505]a
Initial performance test to
demonstrate scrubber control
efficiency [§63.2505]
Continuous monitoring of
TOC concentration using CEMS
(also comply with Appendix F
procedure 1 of 40 CFR part 60)
scrubber liquid flow
pH or caustic strength
inlet gas flow rate
gas temperature exiting
combustion temperature
Correct for supplemental gas to 3%
02 [§63.24500X5)]
A-30
-------
Table A-8. Specific Consolidation Approach for Case Study 5 (continued)
Requirement
Calibration
Recordkeeping
MACT subparts
GGG
(PhRMA)
/
FFFF
(MON)
Option 1 Option 2
Annual calibration of
temperature monitoring device [§63.1258(b)(l)(vii)] and
scrubber liquid flowrate [§63.1258(b)(l)(ii)], unless manufacturer's
specifications are more stringent
For all other parametric monitors, calibrate according to manufacturer's
specifications
Keep 15-minute monitoring data, not daily or hourly averages
[§63.1259(b)(l)]
' The 95% option is selected because it is a simpler alternative than using a CEMS.
As noted in Tables 1 through 8 in the main body of this document, there are some slight
differences in requirements between the two standards; we have concluded that for this case,
compliance with the requirements described above will ensure compliance with both standards.
We note the following differences and our rationale for selection of the overlying option:
D If complying with the alternative standard for organic HAP, subpart FFFF requires a
correction for supplemental gasses to correct outlet concentrations to 3 percent
oxygen. Subpart GGG also requires this correction, but provides an alternative
consisting of maintaining adequate temperature and residence time. Subpart FFFF
provides no such alternative; therefore, compliance with the alternative standard will
require the 3 percent correction.
D Subpart FFFF requires the use of appendix F procedure 1 of 40 CFR 60 for CEMS.
Subpart GGG does not.
D Subpart FFFF requires continuous monitoring of scrubber pH or caustic strength,
while subpart GGG allows daily monitoring
D Subpart FFFF requires calibration of parameter monitoring instruments according to
manufacturer's specifications, while subpart GGG specifies monitoring frequency
and calibration accuracy for some parameter monitors. In order to comply with both
standards, an owner or operator would have to monitor at least as frequently and to
the accuracy requirements required in subpart GGG and more frequently and to
narrower accuracy if the manufacturer's specifications required it. For devices not
specified in subpart GGG, the owner or operator would follow manufacturer's
specifications as provided in subpart FFFF.
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D Subpart GGG requires keeping records of each measurement, not daily or hourly
averages.
In addition, we note that subpart GGG allows the shutdown of a centralized combustion
control device as long as upstream devices are operational; subpart FFFF does not. Therefore,
the owner or operator could not shutdown a centralized control and comply with the
requirements of subpart GGG if processes subject to subpart FFFF were operating.
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Case Study 6Area 6
Overview
General Description
Area 6 contains equipment used to manufacture Product A, a PAI, and 3 other
compounds (Products B, C, and D), one of which is an intermediate in the production of
Product A. The permit application indicates that generally all equipment is connected to the vent
system which is in turn controlled with an incinerator. Figure A-l 1 contains a simplified flow
diagram of the equipment and does not specifically indicate connections to the waste gas
incinerator. From the diagram, the manufacture of intermediates is accomplished in reactor 5,
while the PAI synthesis occurs in reactor 1. The intermediate used in the production of
Product A is not considered a PAI integral intermediate because it is stored prior to further
processing (although under subpart MMM you may elect to consider any intermediate process
for a PAI as a PAI process unit; thus, Product B could be subject to subpart MMM). Therefore,
Products B, C, and D are subject to subpart FFFF and Product A is subject to subpart MMM.
Because the MON products are manufactured in different processing equipment, these products
can be manufactured at the same time as the PAI product.
HAP Emissions Information
HAP emissions from processing equipment consist of chlorine, HC1, and methanol.
Emissions of 234 Ib/yr of methanol and 258 Ib/yr of HC1 are reported from the incinerator stack,
based on information contained in the permit application for Building No. 4.
Identification of Process Units
The boundaries of the dedicated PAI process unit and the remaining nondedicated
MCPUs are presented in Figure A-l 1.
General Discussion of MACT Requirements
Table A-9 contains a general description of applicable requirements for sources in
Area 6. Individual processes manufacturing MON products, such as Products B, C, and D,
would likely trigger MON process vent control requirements. Production of the PAI Product A
would also trigger process vent control requirements. The methanol storage tank and equipment
leaks would also be subject to applicable requirements. The methanol storage tank would be
assigned to Process A because the predominant use is for this process.
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2nd Product:
Raw Materials
[Centrifuge |
T
Product
Brine Disposal
Product A
PAI Process
Unit
Figure A-ll. Process flow diagram for production in Area 6.
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Table A-9. General MACT Requirements for Case Study 6
Process
A
B, C,D
Rule
PAI
MON
Process vents
Yes. Sum of
uncontrolled
emissions from
process vents
exceeds 330 Ib/yr.
Yes. Sum of
uncontrolled
emissions from
process vents
exceeds
10,000 Ib/yr.
Storage tanks
Yes.
Methanol
storage tank
has capacity
> 10,000 gal.
Assigned to
Process A
Equipment
leaks
Yes.
Components
are in HAP
service >300
hr/yr.
Wastewater
None
Transfer
operations
Not
applicable
No.
Loading
thresholds
are below
cutoffs.
Overlapping Situations and Strategies for Minimizing Overlap
Although there is no specific instance of overlap with respect to pieces of processing
equipment, the afterburner system will be subject to two different MACT standards. Because the
PAI process follows the production process of the intermediate, there is no overlap in MACT
applicability for processing equipment, just the control device. It is unlikely that the PUG
approach could be used. In order for the owner or operator to use the PUG concept, the
production of the Product B intermediate would have to be designated as a PAI process unit.
Then applying the PUG concept for Products B, C, and D might allow compliance with subpart
MMM for all four process units in Area 6. This would only work, however, if products A and B
could be considered the primary product of the PUG.
If the owner or operator could not take advantage of the PUG concept, a consolidation
approach could also be used. Table A-10 illustrates how to consolidate requirements for shared
control devices or waste management units in this case. We assume for the sake of this
discussion that process vents contain halogenated compounds.
Table A-10. Overall Consolidation Approach for Case Study 6
Emission Source
Process Vents
Storage Tanks
Wastewater
Equipment Leaks
Consolidation Strategy
See detailed listing of consolidated requirements for
centralized combustion device in Table A-l 1
Assign tank to subpart FFFF
Comply with subpart FFFF; §63.2535(e)
Comply with subpart MMM; §63.2535(d)
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With the exception of process vents, other emission sources can easily be consolidated as
presented above. For process vents that are subject to both subparts MMM and FFFF and
controlled by one centralized combustion device, there are two basic options: (1) conduct an
initial performance test and set appropriate monitoring parameters to demonstrate continuous
compliance, or (2) equip the scrubber stack with a CEMS to continuously measure TOC and
halogens and hydrogen halides (or, for halogens and hydrogen halides, demonstrate 95 percent
removal from the scrubber). The initial compliance test under option 1 must show either
(1) 98 percent removal of organic HAP from the combustion device and 99 percent removal of
hydrogen halides and halogens from the scrubber following the combustion device or (2) outlet
TOC concentrations less than 20 ppmv and outlet hydrogen halide and halogen concentrations
less than 20 ppmv). To eliminate monitoring requirements under Option 1 on the scrubbers
upstream of the incinerator, the performance demonstration should be conducted when the
scrubbers are not operational.
Since the compliance date of subpart FFFF is later than that of subpart MMM, the owner
or operator must comply with subpart MMM as written until the compliance date of subpart
FFFF, at which time, the facility could report under the subpart FFFF notification of compliance
report its intent and strategy to consolidate requirements, and make necessary permit
modifications under title V. The provision allowing consolidation is §63.1360(i)(4) in subpart
MMM, which prompts the operator to comply with both regulations by implementing a strategy
that will assure compliance under both regulations. Appropriate consolidated requirements for
each compliance strategy are summarized in Table A-l 1.
As noted in Tables 1 through 8 in the main body of this document, there are some slight
differences in requirements between the two standards; we have concluded that for this case,
compliance with the requirements described above will ensure compliance with both standards.
We note the following differences and our rationale for selection of the overlying option:
D If complying with the alternative standard for a combustion device controlling
halogenated streams, subpart FFFF allows an option for continuous compliance
through the monitoring of scrubber operating parameters in lieu of a CEMS;
subpart MMM does not. Therefore, consolidation would requires a CEMS for
HC1 and chlorine.
D If complying with the alternative standard for organic HAP, subpart FFFF
requires a correction for supplemental gases to correct outlet concentration to
3 percent O2. Subpart MMM also requires this correction, but provides an
alternative consisting of maintaining adequate temperature and residence time.
Subpart FFFF provides no such alternative; therefore, compliance with the
alternative standard will require the 3 percent correction.
D Subpart FFFF requires the use of appendix F procedure 1 of 40 CFR 60 for
CEMS. Subpart MMM does not.
D Subpart FFFF requires continuous monitoring of scrubber pH or caustic strength,
while subpart MMM allows daily monitoring.
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Subpart FFFF requires calibration of parameter monitoring instruments according
to manufacturer's specifications, while subpart MMM specifies monitoring
frequency and calibration accuracy for some parameter monitors. In order to
comply with both standards, an owner or operator would have to monitor at least
as frequently and to the accuracy requirements required in subpart MMM and
more frequently and to narrower accuracy if the manufacturer's specifications
required it. For devices not specified in subpart MMM, the owner or operator
would follow manufacturer's specifications as provided in subpart FFFF.
Subpart MMM requires keeping records of each measurement, not daily or hourly
averages.
Table A-ll. Specific Consolidation Approach for Case Study 6
Requirement
Organic HAP
Control
Requirement
Halogenated
Stream Control
Requirement
Initial
Compliance
Demonstration
Monitoring
Calibration
Recordkeeping
MACT subparts
MMM
(PhRMA)
/
/
/
FFFF
(MON)
/
/
/
/
Option 1
98% or to < 20 ppmv
[Table 2 to subpart FFFF]
99% control or hydrogen
halides and halogens or to <20
ppmv [Tables 1 and 2 to subpart
FFFF]
Initial performance test to
demonstrate 98% or 20 ppmv,
99% or 20 ppmv based on worst
case
Continuous monitoring of
scrubber liquid flow,
pH or caustic strength
inlet gas flow rate
gas temperature exiting
combustion temperature
Annual calibration of
temperature monitoring device
scrubber liquid flowrate [§63.13
specifications are more stringenl
For all other parametric monitors,
manufacturer's specifications. [§6
Option 2S
Alternative Standard: concentration
standard of 20 ppmv HAP and
20 ppmv hydrogen halides and
halogens [§63.2505]
CEMS forHCl/C!2 monitoring
Continuous monitoring of
TOC concentration using CEMS
(also comply with appendix F
procedure 1 of 40 CFR part 60)
HC1/C12
Correct for supplemental gas to 3%
02. [§63.2450(j)(5)]
§63.1366(b)(l)(vii)]and
66(b)(l)(ii)], unless manufacturer's
t
calibrate according to
3.996(c)(l)]
Keep 15-minute monitoring data, not daily or hourly averages
[§63.1259(b)(l)]
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